Serbian Integrated Hazardous Waste Management Plan€¦ · ““Improvement of hazardous waste...

““Improvement of hazardous waste management in the Republic of Serbia - IWHMS“ 1

Serbian Integrated Hazardous Waste

Management Plan

April 2017

2 “Improvement of hazardous waste management in the Republic of Serbia - IWHMS“

Project partners:

Ministry of Agriculture and Environmental Protection

1, Omladinskih Brigada str., 11070 New Belgrade

Republic of Serbia

Umweltbundesamt

Environment Agency Austria

Spittelauer Lände 5

1090 Vienna

AUSTRIA

and

Federal Ministry for the Environment, Nature Conservation, Building and Nuclear Safe‐ty (BMUB) Köthener Str. 2‐3 10963 Berlin (Germany)

Disclaimer:

This publication has been produced with the financial assistance of the European Un‐

ion. The contents of this publication are the sole responsibility of the Twinning Part‐

ners, Serbian Ministry of Agriculture and Environmental Protection and Environment

Agency Austria, and can under no circumstances be regarded as reflecting the position

of the European Union.

Cover photographs: ©iStockphoto.com/olaf herschbach, © Thomas Reimer – Fotolia.com, © patrkslezak – Fotolia.com

Approvals

Name

Prepared by

Brigitte Karigl, Karl‐Heinz Striegel, Milla Neu‐

bauer, Maria Tesar

Approved by MS Project Leader Brigitte Karigl

Approval by BC Project Leader Radmila Šerović


Twinning Project

Project title Improvement of hazardous waste management in the Republic of

Serbia – IHWMS

Project number SR 13 IB EN 02

Project duration May 2015 – May 2017

Project budget 1,000,000 €

Beneficiary country (BC) Republic of Serbia

Commissioned/financed

by

European Commission, Instrument for Pre‐accession Assistance

(IPA) of the European Union

Project partners

Ministry of Agriculture and Environmental Protection

Umweltbundesamt ‐ Environment Agency Austria

and

Federal Ministry for the Environment, Nature Conservation, Build‐

ing and Nuclear Safety (BMUB)‐Germany

BC project leader Radmila Šerović

BC counterpart Jelena Tesla

MS project leader Brigitte Karigl

Overall project objecti‐

ves

To assist Serbia to meet environmental Acquis through institution‐

al building and improvement of environmental infrastructure

Project purpose

Development and improvement of waste management system, by

completing legislation and strategic planning and implementation

framework for managing special hazardous waste streams in com‐

pliance with EU standards and Serbian legislation


TABLE OF CONTENTS

1 INTRODUCTION ....................................................................... 12

1.1 Overall waste problematic ................................................................. 12

1.2 Role of the plan in waste management planning ............................ 12

1.3 Consultation process ......................................................................... 14

2 LEGAL FRAMEWORK FOR THE MANAGEMENT OF HAZARDOUS WASTE ............................. 15

2.1 Serbian policy and legislation for hazardous waste ....................... 15

2.1.1 Waste Management Act ........................................................................ 15

2.1.2 National Waste Management Strategy ................................................. 16

2.1.3 Specific by-laws and other laws of concern .......................................... 17

2.2 EU policy and legislation for hazardous waste ............................... 18

2.2.1 Waste Framework Directive .................................................................. 20

2.2.2 EU Directives on specific waste streams .............................................. 22

2.2.3 EU Directives on Waste Treatments ..................................................... 29

2.2.4 Waste related aspects of theIndustrial Emissions Directive ................................................................................................ 30

2.2.5 Waste shipment Regulation .................................................................. 32

2.2.6 European Agreement Concerning the International Carriage of Dangerous Goods (ADR) ................................................... 33

3 ORGANISATION OF WASTE MANAGEMENT, INCLUDING DIVISION OF RESPONSIBILITIES BETWEEN PUBLIC AND PRIVATE SECTOR IN THE AREA OF HAZARDOUS WASTE MANAGEMENT......................................................................... 34

3.1 Republic of Serbia / Ministry of Agriculture and Environmental Protection .................................................................. 36

3.1.1 Sector on Planning and Management in the Environment .......................................................................................... 36

3.1.2 Sector on Environmental Inspections ................................................... 37

3.2 Environment Protection Agency – SEPA ......................................... 37

3.3 Republic Statistical Office .................................................................. 38

3.4 Expert Waste testing organization .................................................... 39

3.5 Autonomous Province Vojvodina ..................................................... 39

3.6 The local self-government unit .......................................................... 40

3.7 Joint waste management of local self-government units ...................................................................................................... 41

3.8 Standing conference of towns and municipalities .......................... 42

3.9 Ministry of Labour, Employment, Veteran and Social Affairs ....................................................................................... 42

3.10 Private sector participation ................................................................ 43


4 CURRENT STATUS OF THE WASTE MANAGEMENT REGARDING HAZARDOUS WASTE ...................................................................................... 45

4.1 Qualitative Characterization of hazardous waste ............................ 45

4.1.1 Waste sources of hazardous waste ...................................................... 45

4.1.2 Composition of hazardous waste .......................................................... 46

4.1.3 Overview on waste codes for hazardous wastes .................................. 47

4.2 Quantitative Characterization of hazardous waste ......................... 48

4.2.1 Quantities of hazardous wastes generated in Serbia ........................... 49

4.2.2 Origin of hazardous wastes in Serbia ................................................... 53

4.2.3 Quantities of hazardous wastes treated in Serbia ................................ 57

4.2.4 Quantities and waste types of hazardous waste landfilled in Serbia ................................................................................. 58

4.2.5 Quantities and waste types of hazardous waste used for energy recovery in Serbia ................................................................ 60

4.2.6 Quantities and waste types of hazardous waste treated in operations aiming at recycling/material recovery in Serbia .................................................................................................... 62

4.2.7 Treatment of the hazardous waste from the construction sector ................................................................................ 64

4.2.8 Treatment of the hazardous waste from the health sector/medical waste............................................................................. 65

4.2.9 Quantities of hazardous wastes imported/exported to/from Serbia ........................................................................................ 66

4.2.10 Generation, treatment and shipment of special waste streams ................................................................................................. 67

4.2.11 Generation and treatment of PCB waste and other wastes containing POPs ....................................................................... 68

4.2.12 Historical quantities of hazardous waste .............................................. 69

4.2.13 Summarizing illustration of the generation and treatment of hazardous wastes in Serbia ............................................. 70

5 EXISTING WASTE COLLECTION SYSTEM AND NETWORK OF LARGE WASTE RECOVERY AND DISPOSAL FACILITIES INCLUDING ANY TREATMENT OF WASTE OILS, HAZARDOUS WASTE AND SPECIAL WASTE STREAMS ............................ 72

5.1 Present collection system for hazardous waste .............................. 72

5.1.1 Collection of hazardous waste from industry and commerce ............................................................................................. 72

5.1.2 Collection of hazardous waste from the construction sector .................................................................................................... 72

5.1.3 Collection of hazardous waste from the medical sector ....................... 73

5.1.4 Collection of hazardous waste from households .................................. 73

5.1.5 Collection of hazardous waste streams covered by extended producer responsibility systems ............................................ 74

5.1.6 Collection of PCB waste and other wastes containing POPs ..................................................................................................... 75

5.2 Existing treatment facilities for hazardous wastes ......................... 75

5.2.1 Incineration ............................................................................................ 76


5.2.2 Landfills ................................................................................................. 76

5.2.3 CP-plants .............................................................................................. 78

5.2.4 Further treatment plants for hazardous waste ...................................... 78

5.2.1 Summarizing illustration of the current status of the treatment of hazardous wastes in Serbia ............................................. 79

6 EXPECTED TYPES, QUANTITIES, AND ORIGIN OF HAZARDOUS WASTE THAT WILL BE PRODUCED IN THE REPUBLIC OF SERBIA, IMPORTED OR EXPORTED INTO ANOTHER COUNTRY, INCLUDING ESTIMATIONS RELATED TO GENERATION OF SPECIFIC WASTE STREAMS ................................................................... 80

6.1 Introduction ......................................................................................... 80

6.2 Forecasts for selected waste categories .......................................... 80

6.3 Summarizing illustration of the expected types and quantities of hazardous waste streams in Serbia ........................... 88

7 ASSESSMENT OF NEEDS FOR NEW COLLECTION SYSTEM, ADDITIONAL INFRASTRUCTURE IN WASTE MANAGEMENT FACILITIES IN COMPLIANCE WITH SELF- SUFFICIENCY AND PROXIMITY PRINCIPLES, AND AS NECESSARY, INVESTMENTS INTOTHE CONSTRUCTION OF SUCH INFRASTRUCTURE.................................................................. 91

7.1 Options for the collection of hazardous wastes .............................. 91

7.1.1 Options for the collection of hazardous waste from industry and commerce ......................................................................... 91

7.1.2 Options for the collection of hazardous waste from the construction sector ................................................................................ 92

7.1.3 Options for the collection of hazardous waste from the medical sector ....................................................................................... 93

7.1.4 Options for the collection of hazardous waste from households ............................................................................................ 94

7.1.5 Options for the collection of hazardous agrochemicals’ and industrial packaging waste ............................................................. 95

7.1.6 Options for the collection of waste oils .................................................. 96

7.1.7 Options for the collection of hazardous waste streams covered by extended producer responsibility systems ......................... 98

7.1.7.1 Options for the collection of waste batteries and accumulators 98 7.1.7.2 Options for the collection of WEEE 100 7.1.7.3 Options for the collection and management of ELVs 102

7.1.8 Options for the collection of PCB waste and other wastes containing POPs ..................................................................... 103

7.1.9 Transboundary shipment of hazardous waste .................................... 104

7.2 Options for the treatment, recovery and disposal of hazardous wastes ............................................................................. 104

7.2.1 Available treatment, recovery and disposal technology for hazardous wastes .......................................................................... 108

7.2.1.1 Landfilling of Hazardous waste 108


7.2.1.2 Incineration of hazardous waste 109 7.2.1.3 Physical-chemical treatment of hazardous wastes 114 7.2.1.4 Recycling, reuse and prevention of hazardous waste 116

7.2.2 Options for the treatment, recovery and disposal of hazardous waste from industry and commerce .................................. 117

7.2.3 Options for the treatment, recovery and disposal of hazardous waste from the construction sector ................................... 118

7.2.4 Options for the treatment, recovery and disposal of hazardous waste from the medical sector .......................................... 120

7.2.5 Options for the treatment, recovery and disposal of hazardous waste from households ..................................................... 122

7.2.6 Options for the treatment, recovery and disposal of hazardous agrochemicals’ and industrial packaging waste ................................................................................................... 122

7.2.7 Options for the treatment, recovery and disposal of waste oils ............................................................................................ 124

7.2.8 Options for the treatment, recovery and disposal of hazardous waste streams covered by extended producer responsibility systems .......................................................... 126

7.2.8.1 Treatment of waste batteries and accumulator, 126 7.2.8.2 Treatment of WEEE 128 7.2.8.3 Treatment of ELVs 133

7.2.9 Options for the treatment, recovery and disposal of PCB waste and other wastes containing POPs .................................. 137

7.2.10 Conclusions on the need of new installations ..................................... 143

7.3 Estimated investment and operational costs for appropriate waste management options ........................................ 151

7.3.1 Estimated investment and operational costs for the hazardous waste management infrastructure ..................................... 152

7.3.1.1 Estimated investment and operational costs for the collection infrastructure of hazardous waste 152

7.3.1.2 Estimated investment and operational costs for hazardous waste storage facilities 154

7.3.1.3 Estimated investment and operational costs for physical-chemical treatment plants 155

7.3.1.4 Estimated investment and operational costs for the incineration and the energetic re-use of hazardous waste as fuel 161

7.3.1.5 Estimated investment and operational costs for landfills 167 7.3.1.6 Estimated investment costs for a central treatment and

disposal facility for hazardous waste 171

7.3.2 Estimated investment and operational costs for specific waste stream covered by extended producer responsibility systems ......................................................................... 174

7.3.2.1 Estimated investment and operational costs for hazardous C&D waste management including asbestos waste management 174

7.3.2.2 Estimated investment and operational costs for medical hazardous waste management 177

7.3.2.3 Estimated investment and operational costs for hazardous packaging waste management 180

7.3.2.4 Estimated investment and operational costs for waste oil management 181

7.3.2.5 Estimated investment and operational costs for batteries and accumulators management 185


7.3.2.6 Estimated investment and operational costs for WEEE management 188

7.3.2.7 Estimated investment and operational costs for end-of-life-vehicels 194

7.3.2.8 Estimated investment and operational costs for PCB-waste management 195

7.3.2.9 Estimated investment and operational costs for POP waste management 196

7.3.3 Conclusions ......................................................................................... 197 7.3.3.1 Total capital investment in Serbia 197 7.3.3.2 Operational costs in Serbia 201

8 SOURCES AND AMOUNTS OF FINANCIAL FUNDS FOR REALISATION OF ALL WASTE MANAGEMENT MEASURES FOR HAZARDOUS WASTE .................................................................................... 202

8.1 Estimated present waste management costs ................................ 203

8.2 Options for the financing of the management of hazardous waste ............................................................................... 207

8.2.1 Funding of activities and financing of investment measures ............................................................................................ 207

8.2.2 Public and private sector financing of the hazardous waste infrastructure program .............................................................. 209

8.2.2.1 Available financial resources within the Republic of Serbia 210 8.2.2.2 Reduction measures for estimated financial deficit 211 8.2.2.3 Potential international sources of financing to cover the deficit 212

8.2.3 Indicative financial plan ....................................................................... 214 8.2.3.1 Instruments to cover financial deficit 215 8.2.3.2 Conclusion on financing 218

8.3 Financing and measures for establishing the waste management system ........................................................................ 220

9 DETERMINATION OF OBJECTIVES ..................................... 221

9.1 Key principles in hazardous waste management ....................... 221

9.2 Strategic objectives regarding hazardous industrial and commercial waste management .............................................. 223

9.3 Overall objectives regarding waste prevention of hazardous waste ............................................................................... 225

9.4 Overall objectives regarding the collection of hazardous waste ............................................................................... 225

9.5 Objectives regarding the integrated management (collection, reuse, recycling, energetic recovery, treatment, and disposal) of hazardous waste ................................ 226

9.5.1 Objectives for hazardous C&D waste including asbestos waste management ............................................................. 227

9.5.2 Objectives for medical waste management ........................................ 233

9.5.3 Objectives for hazardous waste management from households .......................................................................................... 233

9.5.4 Objectives for hazardous packaging waste management ....................................................................................... 233

9.5.5 Determination of objectives for waste oil management ...................... 235


9.5.6 Determination of objectives for waste batteries and accumulators’ management ............................................................... 237

9.5.7 Determination of objectives for WEEE management .......................... 237

9.5.8 Determination of objectives for ELV management ............................. 239

9.5.9 Determination of objectives for PCB and other POP waste management (Stockholm Convention) ..................................... 240

10 MEASURES AND GUIDELINES INCLUDING MANNER AND DEADLINES FOR IMPLEMENTATION OF THE NATIONAL PLAN .................... 244

10.1 Measures ............................................................................................ 244

10.1.1 Measures concerning different fields of concern ................................ 244 10.1.1.1 Regulatory instruments 244 10.1.1.2 Operative instruments 251 10.1.1.3 Market based instruments 260 10.1.1.4 Information based instruments 264 10.1.1.5 Voluntary instruments and voluntary agreements 266

10.1.2 Measures concerning hazardous waste streams ............................... 267 10.1.2.1 Measures for hazardous waste management from industry

and commerce 267 10.1.2.2 Measures for hazardous C&D waste management including

asbestos waste 267 10.1.2.3 Measures for hazardous medical waste management 272 10.1.2.4 Measures for hazardous waste management from

households 274 10.1.2.5 Measures for hazardous packaging waste management 276 10.1.2.6 Measures for waste oil management 277 10.1.2.7 Measures for waste from batteries and accumulators

management 282 10.1.2.8 Measures for WEEE management 285 10.1.2.9 Measures for ELV management 289 10.1.2.10 Measures for the PCB and POP management

(Stockholm Convention) 292

10.2 Assignment of responsibilities for implementation of measures ....................................................................................... 301

10.3 Assessment of useful effects and sustainability of application of economic and other instruments in waste management, with undisturbed functioning of internal market .............................................................................. 301

11 CRITERIA FOR SITE IDENTIFICATION AND NECESSARY CAPACITIES OF NEW ESTABLISHMENTS FOR RECOVERY AND/OR DISPOSAL OF WASTE .......................................................... 302

11.1 Search Criteria and search procedure for hazardous waste landfill sites ......................................................... 302

11.1.1 Significance of geological barrier ........................................................ 303

11.1.2 Stepwise approach to suitable sites .................................................... 303 11.1.2.1 Exclusion criteria and minimum requirements 304 11.1.2.2 Evaluative criteria 305 11.1.2.3 Additional site selection criteria 305

11.1.3 Systematics of searching procedure ................................................... 305

11.1.4 Site selection ....................................................................................... 306


11.2 Search criteria for other hazardous waste recovery and treatment plants ......................................................................... 306

11.2.1 Exclusion criteria and minimum requirements .................................... 306

11.2.2 Additional site selection criteria ........................................................... 307

12 REFERENCES ........................................................................ 308

13 ANNEX .................................................................................... 309

13.1 Part A – Information on the consultation process ........................ 309

13.1.1 Members of the planning team of this WMP ....................................... 309


ABBREVIATIONS

ADR European Agreement concerning the International Carriage of Dangerous Goods by Road

NGO Non-governmental organization

IPPC Integrated Prevention and Control of Pollution

OG Official Gazette

EU European Union

WEEE Waste Electrical and Electronic Equipment

ELV End-of-life vehicle

SEIA Strategic Environmental Impact Assessment

IED Industrial Emission Directive

PCB Polychlorinated biphenyls and polychlorinated terphenyls

MAEP Ministry for Agriculture and Environmental Protection

LSG Local self-government unitSEPASerbian Environmental Protection Agency

EMAS Eco-Management und Audit Scheme

POP Persistant organic pollutants

AP Autonomous Province

SEPA Serbian Environmental Protection Agency

SCTM Standing Conference of Towns and Municipalities

LoW European List of Waste


1 INTRODUCTION

The overall objective of this Waste Management Plan is to establish an effective management system - for hazardous waste in Serbia - including legal, institutional and technical aspects.

In order to achieve this goal an assessment of the current situation regarding hazardous waste was performed and gaps in the legal framework and its practical implementation were identified. Furthermore, in this plan information on options for the management of hazardous waste is pro-vided in order to identify necessary steps for improving hazardous waste management in Ser-bia.

The main goals of the plan are summarized in Chapter 9. Information on the implementation of this plan - i.e. planned measures to achieve these goals, the responsibility for their implementa-tion and timelines - is provided in Chapter 10 “Action Plan for Achieving the Objectives”.

1.1 Overall waste problematic

In Serbia a national Waste Management Strategy for the period 2010-2019 was adopted in

2010 (Official Gazette of the Republic of Serbia, no. 29/10), which defines policy objectives up

to 2019. According to this Waste Management Strategy “The responsibility of the Government

and the National Assembly is to establish a legal framework for sustainable waste management,

economic instruments for waste management implementation and public awareness raising, ini-

tiation of dialogue between the interested parties, in order to establish waste management part-

nerships”.

According to the Serbia 2015 Progress Report1 some progress has been made in the field of

waste management, e.g. starting the regional waste management centre for the Subotica dis-

trict, which will serve approximately 280 000 people and the adoption of a regulation on the plan

for reducing packaging waste 2015-2019. However, several fields, where improvement is need-

ed were identified. Non acquis compliant landfills need to be closed more quickly. Additional ef-

forts are needed to meet relevant targets for glass- and metal-containing packaging waste.

More national investment and improvements to address systemic weaknesses in the implemen-

tation of environmental projects will be needed if management of all special waste streams is to

comply with EU requirements. Full alignment with the Waste Framework Directive remains to be

achieved and enforcement of waste legislation needs to improve.

1.2 Role of the plan in waste management planning

The national Waste Management Strategy for the period 2010-2019 inter alia requires the Gov-

ernment to prepare and adopt national waste management plans, which should address issues

associated with specific waste streams.

1 European Commission (2015): Commission Staff Working Document, SERBIA 2015 REPORT.


Article 11 of the Law on Waste Management ("Official Gazette of RS", no. 36/2009, 88/2010 and 14/2016) stipulates that the national waste management plan shall contain the following:

Expected types, quantities and origin of waste that will be produced in the Republic of Ser-bia, importer or exported into another country, including estimations related to generation of special waste streams;

Existing waste collection system and network of large waste re-use and disposal facilities, including any treatment of waste oils, hazardous waste and special waste streams;

Assessment of needs for new collection system, closing down of existing waste manage-ment facilities, additional infrastructure in waste management facilities in compliance with self-sufficiency and proximity principles, and as necessary, investments into the construc-tion of such infrastructure;

Plan for implementation of reduction of quantities of biodegradable waste disposed on land-fills, measures for the achievement of goals for disposal this type of waste, especially, for recycling, composting, production of biogas or re-use of materials/energy recovery;

Criteria for site identification and necessary capacities of new establishments for re-use and/or disposal of waste;

Organisation of waste management, including division of responsibilities between public and private sector in the area of waste management;

Sources and amounts of financial funds for realisation of all waste management measures;

Assessment of useful effects and sustainability of application of economic and other instru-ments in waste management, with undisturbed functioning of internal market;

Measures and guidelines for implementation of the national plan;

Manner and deadlines for implementation of the national plan.

Specific waste stream plans for batteries and accumulators, waste oils, electric and electronic

waste, asbestos waste, medical waste, hazardous construction and demolition waste, POPs

waste and end-of-life vehicles have been drafted but not adopted. However, they became part

of this Integrated Hazardous Waste Management Plan, based on the provisions of the amended

Law on Waste Management.

On the one hand, these specific plans include overlaps in information and in the measures that

were defined to improve waste management. On the other hand, synergies related to the man-

agement of several different hazardous waste streams are not sufficiently reflected.

This integrated hazardous waste management plan is meant to:

give an overview on the existing situation;

identify gaps in the current legislation and problems in the practical implementation;

inform about options for hazardous waste management and

identify steps necessary to establish an effective management system for hazardous waste in Serbia.

The geographical coverage of this plan is the whole territory of the Republic of Serbia. The time

horizon of the plan is 2018-2023. In 2023 this plan will be reviewed.

After its latest amendment the Law on Waste Management ("Official Gazette of RS", no.

36/2009, 88/2010 and 14/2016) requires the enactment of one National Waste Management

Plan which means that all the obligations and guidance stipulated in the waste management

plans on specific waste streams need to be introduced and compiled to one alone standing

document.


1.3 Consultation process

In the course of developing this Integrated Hazardous Waste Management Plan three work-shops were held with participation of relevant Serbian stakeholders: the relevant Ministries, Re-gional Administrations (including the autonomous province of Vojvodina, City of Belgrade), and other stakeholders including operators of waste treatment plants, Chamber of Commerce, la-boratories for waste characterisation, NGOs et. al. 2.

The focus of these workshops was:

to discuss available information about the current status of hazardous waste management in Serbia (waste generation, waste treatment and collection and treatment infrastructure)

to discuss appropriate management options for hazardous wastes;

to agree on objectives for the management of hazardous waste in Serbia and

to discuss and agree on measures necessary to achieve these objectives.

Interim results and background information were regularly presented to the involved stakehold-ers and put to discussion. Comments of stakeholders were taken into due consideration when preparing the final draft of the Integrated Hazardous Waste Management Plan.

2 A list of the members of the planning team and of the participates of the workshops are provided in the Annex (Chapter

13.1)


2 LEGAL FRAMEWORK FOR THE MANAGEMENT OF HAZARDOUS WASTE

2.1 Serbian policy and legislation for hazardous waste

2.1.1 Waste Management Act

The Waste Management Act (Official Gazette of the RS, no. 36/09, as amended) is the main le-gal instrument establishing the waste management policy in Serbia. It defines the types of waste and its classification, waste management planning, stakeholders, waste treatment operations, obligations and liability with regard to waste management, special waste streams management, requirements and procedures for the issuance of permits, shipment of waste, reporting, eco-nomic instruments for waste management, and the enforcement procedures.

According to the Waste Management Act, waste management consists of a set of activities of joint interest which comprise implementation of prescribed action plans to be carried out within waste collection, transport, storing, treatment and disposal, including supervision of these activi-ties and responsibility for waste management facilities and aftercare. The Waste Management Act provides for transitional periods for achieving compliance with its provisions.

Article 6 (“Principles”) stipulates the basic principles of waste management, among others the “responsibility principle” and the “polluter pays principle”. The responsibility principle means, that producers, importers, distributors and sellers of products that affect the increase of the waste quantity shall be responsible for the waste generated by their activities. The polluter pays princi-ple means, that the polluter shall bear the full costs of consequences of their activities.

In Article 25 (“Responsibilities of Product Manufacturer”) more specific obligations regarding the responsibility of producers are outlined. Firstly the product manufacturer has some general obli-gations regarding the production process and regarding the product. Secondly it is stipulated, that manufacturer or importer whose product becomes hazardous waste upon its use shall take such waste over after the use of product, free of charge. In order to fulfil this second obligation the manufacturer may authorise other legal entity to take the products over upon their use, on behalf of the manufacturer and for their account.

Article 79 stipulates that producer and/or importer of products which, after being used, become specific waste streams, shall pay a fee when first placing the product in the Serbian market. The funds collected this wayshall be made available for Waste management purposes (articles 80 and 81).

Article 11 stipulates that national waste management plans shall be developed for managing dif-ferent waste streams. Article 11 furthermore specifies the obligatory contents 1.2of the national waste management plans.


2.1.2 National Waste Management Strategy

National Strategy for Waste Management for the period 2010 - 2019

The National Strategy for Waste Management as part of a program for accession to the EU was adopted in 2003 and revised in 2010 and currently covers the period until 2019. It aims at estab-lishing the necessary policy conditions for efficient and sustainable waste management.

Main principles have been fixed in the strategy like the precautionary principle and the polluter pays principle. Many of the proposed instruments will be on the accountability of producers. The strategy underlines the necessity of implementing the waste management hierarchy of the EU Waste Framework Directive on the one hand and the realization of a regional adapted approach on the other hand, searching for the most suitable environmental options for Serbia.

The Strategy covers both hazardous andnon-hazardous wastes. It sets for both of them short-term objectives for the period 2010-2014 and long-term objectives for the period 2015-2019.

Short-term objectives (2010-2014) have been:

harmonization of the national waste management legislation with the EU acquits;

adoption of national plans for specific waste steams;

Development of regional and local waste management plans

increase of the population covered by the organized waste collection;

Development of the system of primary separation of waste in local self-government units;

Establishment of regional centers for waste management with regional landfills, facilities for the separation of recyclable waste, transfer stations etc.

Establishment of a system of central regional storage sites for hazardous waste and con-struction of the plant for physical-chemical treatment of hazardous waste;

Establishment of a system for the management of specific waste streams like waste tires, spent batteries and accumulators, waste oils, ELVs, WEEE, medical waste and waste from pharmaceuticals;

Encouragement of industry for the use of waste as an alternative fuel e.g. in cement plants, steel production plants and other thermal processes;

Improvement of the existing sanitary landfills and of sites with historical pollution from haz-ardous waste.

Long-term objectives (2015-2019) are:

Separation of management activities for hazardous waste from municipal, industrial and commercial management activities for non-hazardous waste;

Establishment of regional waste management centers to be continued;

Provision of capacities for the incineration of organic industrial waste and infectious medical waste;

Enhancing professional and institutional capacities for hazarouds waste management;

Increase the level of re-use and recycling of packaging waste (glass, paper, cardboard, met-al and plastic) up to 25% of generated quantities;

Establishment of a system for management of construction and demolition waste and of as-bestos-containing waste.


The strategy describes in detail a number of measures for hazardous waste management, which cover the whole spectrum of waste technologies.These include:

Establishment of adequate collection and transportation schemes for hazardous waste ;

Establishment of five regional temporary storage sites for hazarouds waste,

Establishment of physical-chemical treatment facilities within the foreseen waste managment center for hazardous waste,

Establishment of two incinerators for thermal treatment of hazardous waste and

Realization of one landfill for hazardous waste.

Hazardous wastes that cannot be treated in Serbia should be collected, temporarily stored and exported to authorized facilities abroad.

2.1.3 Specific by-laws and other laws of concern

The Serbian Waste Management Strategy and the Waste Management Act establish the legal basis for the adoption of a number of by-laws regulating the waste management operations, the specific waste management streams, the classification and shipment of waste and reporting du-ties on waste.

The following by-laws have been identified as important for hazardous waste management in Serbia:

Ministerial order on categories, testing and classification of waste (OG of the RS, No. 56/2010);

Governmental order on conditions, methods and management procedures of waste oils (OG of the RS, No. 71/2010);

Ministerial order on management of medical waste (OG of the RS, No. 78/2010);

Ministerial order on handling asbestos-containing waste (OG of the RS, No. 78/2010);

Ministerial order on spent batteries and accumulators (OG of the RS, No. 78/2010);

Ministerial order on method and management of end-of life vehicles (OG of the RS, 98/2010, adopted on 29/12/2010)

Ministerial order on the list of electric and electronic products, measures of prohibition and restriction of use of electric and electronic equipment containing hazardous substances, methods and procedures of managing waste from electric and electronic products (OG of the RS, 99/2010, adopted on 10/01/2011)

Governmental order on products which after use become separate waste flows, form of daily record on quantity and type of produced and imported products and annual report, method and deadlines for delivering the annual report, entities required to pay a fee, criteria for bill-ing, amount and method of billing and payment of fee (OG of the RS, No. 548/2010).

Draft of Ministerial Order on management of PCB-containing equipment and waste

Draft of Ministerial Order on reporting on waste management


Orders regulating transboundary shipment of waste are: Governmental order on the lists of waste for transboundary shipment of waste and the con-

tent and form of the document, which accompanies the transboundary shipment of waste and its filling-in

Governmental order on determination of specific sorts of hazardous waste which can be im-ported as secondary raw material

Ministerial order on the content of the documentation for transboundary shipment of waste

Orders regulating waste treatment and waste disposal are:

Governmental order on on conditions, method and procedure of thermal waste treatment (OG of the RS, 102/2010, adopted on 13/01/2011)

Governmental order on disposal of waste in landfills (OG of the RS, 92/2010, adopted in 2010).

Other important regulations for the planning of hazardous waste management are:

Law on Integrated Prevention and Control of Pollution

The Law on IPPC (OG of the RS, no. 135/04) transposes in Serbian legislation the IPPC Di-rective (2008/1/EC) and defines the conditions and procedure for issuance of integrated permits for installations which may have a negative impact on human health, environment or tangible assets, the type of installations, supervision and other relevant aspects of environmental pollu-tion prevention or control. The law has to be adapted to the new Industrial Emission Directive IED (see below), soon.

Law on Strategic Environmental Impact Assessment

The Law on Strategic Environmental Impact Assessment ( OG of the RS, no. 135/04) transpos-es into Serbian legislation the SEIA Directive (2001/42/EC) and is the instrument ensuring the integration of the environmental considerations into the sectorial policy. Furthermore, it regu-lates conditions, method and procedures of conducting the strategic assessment of environmen-tal impact during facility planning. Finally it determines the public participation in the SEIA pro-cedure.

2.2 EU policy and legislation for hazardous waste

EU Waste policy

The European Unionsapproach to waste management is based on the following principles:

Waste prevention as a key factor in any WM strategy, reducing the amount of waste gener-ated and reducing its hazardousness by reducing the presence of dangerous substances in products.

Recycling and reuse: The European Commission has defined several specific 'waste streams' for priority attention to reduce their overall environmental impact. This includes packaging waste, end-of-life vehicles, batteries and accumulators, electrical and electronic waste. EU directives now require Member States to introduce legislation on waste collec-tion, reuse, recycling and disposal of these waste streams.


Improving final disposal and monitoring: Wherever possible, unavoidable and unrecyclable waste should be safely incinerated, with landfill only used as a last solution. Both methods need close monitoring because of their potential environmental damage. The EU approved directives (see below) setting strict guidelines for landfill management and waste incinera-tors.

The Sixth Environment Action Program (Decision 1600/2002/EC), which was guiding European environment policy during the years 2002-2012, identifiedwaste prevention and management as one of four top priorities. Its primary objective wasto decouple waste generation from economic activity, so that EU economic growth wouldno longer be accompanied by more environmental damage. New waste prevention initiatives, better use of resources and more sustainable con-sumption patterns were to significantly cut in the amount of waste generated.

The Thematic Strategy on the Prevention and Recycling of Waste (COM/2005/0666)), which was one of the seven thematic strategies programmed by the Sixth Environment Action Pro-gramme, describes a number of key objectives of its waste policy. These objectives were in-tended to contribute to the reduction of the overall negative environmental impacts of resource use, securing a higher level of environmental protection.

In order to achieve these objectives it was proposed to take forward actions intended to mod-ernize the legal framework relating to waste management. Specific actions recommended in-cluded:

full implementation of existing European legislation;

simplification and modernization of existing legislation;

introduction of life-cycle thinking into waste policy;

promotion of more ambitious waste prevention policies;

development of better knowledge and information about waste prevention instruments;

development of common reference standards for recycling.

The Seventh Environment Action Programme (1386/2013/EU) will be the guideline for European environment policy until 2020 and has special focus on turning waste into a resource. The 7th Environment Action Programme sets the following priority objectives for waste policy in the EU:

To reduce the amount of waste generated;

To maximise recycling and re-use;

To limit incineration to non-recyclable materials;

To phase out landfilling to non-recyclable and non-recoverable waste;

To ensure full implementation of the waste policy targets in all Member States.

In 2015, The European Commission adopted an ambitious Circular Economy Package, which includes revised legislative proposals on waste to stimulate Europe's transition towards a circu-lar economy. The actions proposed in the EU Action Plan for the Circular Economy (COM/2015/0614) shall contribute to "closing the loop" of product lifecycles through greater re-cycling and re-use, and bring benefits for both the environment and the economy.


2.2.1 Waste Framework Directive

The Waste Framework Directive (Directive 2008/98/EC on waste and repealing certain direc-tives) lays down measures to protect the environment and human health by preventing or reduc-ing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving the efficiency of such use. It sets the basic concepts and definitions related to waste management and establishes a legal framework for the treatment of waste within the EU.

The key elements of the Waste Framework Directive are:

The legislation establishes a waste hierarchy: 1. prevention, 2. re-use, 3. recycling, 4. re-covery for other purposes such as energy and 5. disposal.

It confirms the ‘polluter pays principle’ whereby the original waste producer must pay for the costs of waste management.

It introduces the concept of ‘extended producer responsibility’. This may include an duties of manufacturers to accept and dispose of products returned after use.

It makes a distinction between waste and by-products.

Waste management must be carried out without any risk to water, air, soil, plants or animals, without causing a nuisance through noise or smells, or harming the countryside or places of special interest (precautionary principle).

Producers or holders of waste must treat it themselves or have it handled by an officially recognised operator. They require a permit and are inspected periodically.

Competent national authorities must establish waste management plans and waste preven-tion programmes.

Special conditions apply to hazardous waste, waste oils and bio-waste.

It introduces recycling and recovery targets to be achieved by 2020 for household waste (50 %) and construction and demolition waste (70 %).

End-of-waste and by-product regulations

The Waste Framework Directive (Directive 2008/98/EC) introduced two new instruments to en-hance the re-use/recycling of waste materials.

Article 6 of the Waste Framework Directive refers to the “end of waste” of recovered materials. According to this Article, certain specified waste shall cease to be waste provided that:

the substance or object is commonly used for specific purposes;

a market or demand exists for such a substance or object;

the substance or object fulfills the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and

the use of the substance or object will not lead to overall adverse environmental or human health impacts.

The main issue of this provision is to ease the use of certain recovered materials by reducing the bureaucratic burden that is connected with the waste status, provided this doesn’t jeopard-ize the goals of the Waste Framework Directive. This might only be feasible for non-hazardous waste. Several End of Waste – Regulations were enacted during the last few years (iron and al-uminium scrap, copper scrap, glass culets).

Article 5 of the Waste Framework Directive (2008/98/EU) refers to the notion “by-product”. Ac-cording to this Article, a substance or object, resulting from a production process, the primary


aim of which is not the production of that item, may be regarded as not being waste provided that:

further use of the substance or object is certain;

the substance or object can be used directly without any further processing other than nor-mal industrial practice;

the substance or object is produced as an integral part of a production process; and

further use is lawful, i.e. the substance or object fulfils all relevant product, environmental and health protection requirements for the specific use and will not lead to overall adverse environmental or human health impacts.

National waste management plans and prevention programs

According Article 28 of the Waste Framework Directive (2008/98/EC), the minimum require-ments for national waste management plans are:

1. The plans shall, alone or in combination, cover the entire geographical territory of the Mem-ber State concerned.

2. The waste management plans shall set out an analysis of the current waste management situation in the geographical entity concerned, as well as the measures to be taken to im-prove environmentally sound preparing for re-use, recycling, recovery and disposal of waste and an evaluation of how the plan will support the implementation of the objectives and pro-visions of this Directive.

3. The waste management plans shall contain at least the following:

the type, quantity and source of waste generated within the territory, the waste likely to be shipped from or to the national territory, and an evaluation of the development of waste streams in the future;

existing waste collection schemes and major disposal and recovery installations, includ-ing any special arrangements for waste oils, hazardous waste or waste streams ad-dressed by specific Community legislation;

an assessment of the need for new collection schemes, the closure of existing waste in-stallations, additional waste installation infrastructure in accordance with Article 16, and, if necessary, the investments related thereto;

sufficient information on the location criteria for site identification and on the capacity of future disposal or major recovery installations, if necessary;

general waste management policies, including planned waste management technologies and methods, or policies for waste posing specific management problems.

4.Waste management plans may contain the following:

organisational aspects related to waste management including a description of the allo-cation of responsibilities between public and private actors carrying out the waste man-agement;

an evaluation of the usefulness and suitability of the use of economic and other instru-ments in tackling various waste problems, taking into account the need to maintain the smooth functioning of the internal market;

the use of awareness campaigns and information provision directed at the general public or at a specific set of consumers;

historical contaminated waste disposal sites and measures for their rehabilitation.

5. Waste management plans shall conform to the waste planning requirements laid down in Ar-ticle 14 of Directive 94/62/EC and the strategy for the implementation of the reduction of biode-gradable waste going to landfills, referred to in Article 5 of Directive 1999/31/EC.

Prevention programs must also be drawn up, with a view to breaking the link between economic growth and the environmental impacts associated with the generation of waste. These programs are to be communicated by Member Statesto the European Commission.


2.2.2 EU Directives on specific waste streams

Waste oils

Management of waste oils is currently regulated by the Waste Framework Directive (2008/98/EC), which repealed the Directive on waste oils (79/439/EEC).Nevertheless, it might be worth keeping in mind the main contents of the Waste Oil Directive (79/439)/EEC), because untill now waste oil is regulated in Serbia by the Waste Management Act and Governmental order on conditions, methods and management procedures of waste oils, which both trans‐posed the repealed Directive 75/439/EEC on waste oils into the national legislation. The nec‐essary transposition of Article 21 of the Waste Framework Directive on waste oils is under pro‐gress.

According to Article 21 of the Waste Framework Directive, Member States must ensure that waste oils are collected separately, where this is technically feasible.In case of generation of waste oils, they should be re-used incl. material recycling (recovery of base oil components), i.e. refined. Where this process is not feasible or otherwise not used, other methods for recovery may be considered such as combustion with high level of energy recovery. Ultimately, methods for disposal such as chemical destruction (e.g. thermal treatment with destruction of PCB and other organic toxins) or solidification and disposal in landfills may have to be applied or interme-diate storage for later treatment. The Waste Framework Directive stipulates the conditions un-der which this must occur.

If waste oils, according to national legislation, are subject to requirements of regeneration, Member States may prescribe that such waste oils shall be regenerated if technically feasible and, where Articles 11 or 12 of the Waste Shipment regulation (Regulation (EC) No 1013/2006) apply, restrict the transboundary shipment of waste oils from their territory to incineration or co-incineration facilities in order to give priority to the regeneration of waste oils.

Polychlorinated biphenyls and polychlorinated terphenyls (PCBs)

According to Directive 96/59/EC on disposal of polychlorinated biphenyls and polychlorinated terphenyls, Member States must take the necessary measures to ensure that:

used PCBs are disposed of;

PCBs and equipment containing PCBs are decontaminated or disposed of.

Inventories must be compiled of equipment with PCB volumes of more than 5 dm3, which Member Statess had to send to the Commission by September 1999 at the latest. The equip-ment and PCBs contained in the inventories had to be decontaminated or disposed of by 2010 at the latest. Any equipment which is subject to inventory must be labeled.

Directive 96/59/EC also stipulates that Member States must take the necessary measures to ensure that:

PCBs, used PCBs and equipment containing PCBs which is subject to inventory are trans-ferred to licensed undertakings, at the same time ensuring that all necessary precautions are taken to avoid the risk of fire;

any incineration of PCBs or used PCBs on ships is prohibited;

all undertakings engaged in the decontamination and/or the disposal of PCBs, used PCBs and/or equipment containing PCBs obtain permits;

transformers containing more than 0.05% by weight of PCBs are decontaminated under the conditions specified by the Directive.


Within the 3 years following the adoption of this Directive, Member States must draw up plans for the decontamination and/or disposal of inventoried equipment and the PCBs contained therein and plans for the collection and subsequent disposal of equipment not subject to inven-tory.

Waste electrical and electronic equipment (WEEE)

The first WEEE Directive (Directive 2002/96/EC) entered into force in February 2003. The Di-rective introduced obligations for separate collection including collection targets, standards for treatment as well as recovery and recycling rates, specifically for the diverse categories of WEEE. The Directive provided for the creation of collection schemes where consumers return their WEEE free of charge. These schemes aim to increase the recycling and/or re-use of WEEE.

Directive 2002/96/EC has been repealed by the new WEEE Directive (Directive 2012/19/EU), which entered into force in August 2012 and became effective in February 2014. This recast Di-rective introduces stepwise hihger collection targets that will apply will apply from 2016 and 2019. From 2018, the coverage of the Directive will be extended from its current restricted scope to all categories of EEE. The new WEEE Directive also provides Member States tools to fight illegal shipments of WEEE more efficiently, and introduces implementing acts towards the harmonisation of registration and reporting requirements for EEE producers.

In addition, the following pieces of EU legislation have special relevance for the management of WEEE

Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) and

Commission Decision of 3 May 2005 laying down rules for monitoring compliance of Member States and establishing data formats for the purposes of Directive 2002/96/EC of the Euro-pean Parliament and of the Council on waste electrical and electronic equipment (2005/369/EC).

The following targets for the separate collection of WEEE have been set by the recast Directive (2012/19/EU):

From 2016 to 2018: Annual minimum collection rate of 45% of EEE put on the market, calcu-lated on the basis of the total weight of WEEE collected and the average weight of EEE put on the market in the three preceding years.

As of 2019: Annual minimum collection rate of 65% of EEE put on the market, calculated on the basis of the total weight of WEEE collected and the average weight of EEE put on the market in the three preceding years or 85% of WEEE generated on the territory of that Member State.

The best available techniques (BAT) should be used, wenn treatment, recovery or recycling of WEEE is carried out. Establishments or undertakings carrying out treatment operations must optain a permit from the competent authorities in compliance with the Waste Framework Di-rective (2008/98/EC). They are also encouraged to to introduce certified environmental man-agement systems in accordance with Regulation (EC) No 1221/2009 on the voluntary participa-tion by organisations in a Community eco- management and audit scheme (EMAS)


The WEEE Directive (2012/19/EU) sets the following recovery targets, which shall be met by August 2018:

85% in the case of large domestic appliances and automatic dispensers,

75% in the case of small domestic appliances, lighting equipment, electrical and electronic tools, toys, leisure and sports equipment and monitoring and control instruments, and

80% in the case of IT and telecommunications equipment and consumer equip-ment/photovoltaic panels.

For reuse and recycling the WEEE Directive (2012/19/EU) sets the following targets, which also shall be met by August 2018:

80% in the case of discharge lamps,

80% in the case of large domestic appliances and automatic dispensers,

55% in the case of small domestic appliances, lighting equipment, electrical and electronic tools, toys, leisure and sports equipment and monitoring and control equipment, and

70% in the case of IT and telecommunications equipment and consumer equip-ment/photovoltaic panels.

As of August 2018, the following targets for recovery apply according to the Directive (2012/19/EU):

85% in the case of temperature exchange equipment and large equipment

80% in the case of large screens, monitors, and equipment containing screens

75% in the case of small equipment and small IT and telecommunication equipment

As of August 2018, the following targets for recycling and preparing for reuse apply according to the Directive (2012/19/EU):

80% in the case of temperature exchange equipment and large equipment and lamps

70 % in the case of large screens, monitors, and equipment containing screens

55 % in the case of small equipment and small IT and telecommunication equipment

All producers as defined by WEEE Directive must be registered. Producers finance the net costs of collecting (at least from the private or public collection point), treating and recycling all collected WEEE. Basic principles with regard to the financing of WEEE management are set at the level of the Union, and financing schemes have to contribute to high collection rates, as well as to the implementation of the principle of extended producer responsibility. In order to give maximum effect to the concept of extended producer responsibility, each producer should be responsible for financing the management of the waste from his own products. Therefore each producer must, when placing a product on the market, provide a financial guarantee.

For each new type of EEE, producers must provide, within one year after it is placed on the market, information on its reuse and treatment. Such information is to identify the components and materials present in the equipment and the location of dangerous substances and prepara-tions. Such information must be communicated to reuse-centers and treatment / recycling facili-ties.

Member States should provide for effective, proportionate and dissuasive penalties to be im-posed on natural and legal persons responsible for waste management, where they infringe the provisions of this Directive.


Batteries and accumulators and waste batteries and accumulators

Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators (Batteries Directive) has the main objective to minimize the negative impact of batteries and ac-cumulators and waste batteries and accumulators on the environment, thus contributing to the protection, preservation and improvement of the quality of the environment.

The Batteries Directive (2006/66/EC) been submitted to an amending process several times and there are a number of EU regulations with relevance for the management processes of the waste batteries and accumulators.

As regards the producer responsibility, producers of batteries and accumulators and producers of other products incorporating a battery or accumulator are responsible for the waste manage-ment of batteries and accumulators that they place on the market.

The Batteries Directive (2006/66/EC) prohibits the placing on the market of certain batteries and accumulators containing mercury or cadmium. It also promotes a high level of collection and re-cycling of waste batteries and accumulators and improved environmental performance of all op-erators involved in the life cycle of batteries and accumulators.

Waste batteries and accumulators should be separately collected. For portable batteries and accumulators, collection schemes achieving a high collection rate should be established. This means setting up collection schemes to be convenient and free of charge for end-users. Differ-ent collection schemes and financing arrangements are appropriate for the different battery and accumulator types. Where batteries or accumulators are collected together with WEEE, batter-ies or accumulators shall be removed from the collected WEEE.

The Directive sets minimum collection and recycling targets for Member States. Member Statesare obliged to maximize the separate collection of waste batteries and accumulators and to minimize the disposal of batteries and accumulators as mixed municipal waste in order to achieve a high level of recycling. The Directive requires that the following collection rates are achieved:

25% by 26 September 2012 and

45% by 26 September 2016

It is appropriate to calculate the collection rate on the basis of average annual sales in preced-ing years.

Recycling processes should meet the following rates:

recycling of 65 % by average weight of lead-acid batteries and accumulators, including recy-cling of the lead content to the highest degree that is technically feasible while avoiding ex-cessive costs;

recycling of 75 % by average weight of nickel-cadmium batteries and accumulators, includ-ing recycling of the cadmium content to the highest degree that is technically feasible while avoiding excessive costs; and

recycling of 50 % by average weight of other waste batteries and accumulators.

The disposal in landfills or by incineration of waste industrial and automotive batteries and ac-cumulators is prohibited. However, residues of any batteries and accumulators that have under-gone both treatment and recyclinmay be disposed of in landfills or by incineration.


Basic principles for financing the management of waste batteries and accumulators are set through this Directive. Financing schemes should help to achieve high collection and recycling rates by applying the “producer responsibility” principle. All producers as defined by this Di-rective should therefore be registered in order to participate in financing the net costs of collect-ing, treating and recycling all collected batteries and accumulators.

Rules on penalties should be laid down, applicable to infringements of national provisions adopted pursuant to this Directive and all necessary measures shall be taken to ensure that they are implemented. The penalties provided for must be effective, proportionate and dissua-sive. Member States shall notify those measures to the Commission.

End-of life vehicles (ELV)

The main objective of the Directive in general is the harmonization of different national measures concerning ELV in order to minimize the impact of end-of life vehicles on the envi-ronment, thus contributing to the protection, preservation and improvement of the quality of the environment and energy conservation as well as to ensure the smooth operation of the internal market and avoid distortions of competition in the Community.

A Community-wide system should be established in order to ensure coherence between nation-al approaches in attaining the objectives stated above, especially with a view to the design of vehicles for recycling and recovery, to the requirements for collection and treatment facilities, and to the attainment of the targets for reuse, recycling and recovery, taking into account the principle of subsidiarity and the polluter-pays principle.

The key elements of the Directive 2000/53/EC are:

Vehicle and equipment manufacturers must factor in the dismantling, reuse and recovery of the vehicles when designing and producing their products. They have to ensure that new vehicles are:

o reusable and/or recyclable to a minimum of 85 % by weight per vehicle

o reusable and/or recoverable to a minimum of 95 % by weight per vehicle.

They may not use hazardous substances such as lead, mercury, cadmium and hexavalent chromium.

Manufacturers, importers and distributors, must provide systems to collect ELVs and, where technically feasible, used parts from repaired passenger cars.

Owners of ELVs delivered for waste treatment receive a certificate of destruction. This is necessary to deregister the vehicle.

Producers meet all, or a significant part, of the costs involved in the delivery to a waste treat-ment centre. There is no expense for the vehicle’s owner except rare cases where the en-gine is missing or the ELV is full of waste.

Waste treatment centres must apply for a permit or register with the competent authorities.

ELVs are first stripped before further treatment takes place. Hazardous materials and com-ponents are removed and separated. Attention is given to the potential reuse, recovery or recycling of the waste.

Clear quantified targets for annual reporting to the European Commission exist for the reuse and recovery of ELVs. These have become increasingly more demanding.

EU countries report to the European Commission every 3 years on the implementation of the directive.


The legislation applies to passenger vehicles and small trucks but not to big trucks, vintage vehicles and special use vehicles.

The Directive stipulates that Member States shall take the necessary measures to ensure that the following targets are attained by economic operators:

o no later than 1 January 2015, for all end of life vehicles, the reuse and recovery shall be increased to a minimum of 95 % by an average weight per vehicle and year. Within the same time limit, the re-use and recycling shall be increased to a minimum of 85 % by an average weight per vehicle and year.

Asbestos

The objective of the Directive 87/217/EC on the prevention and reduction of environmental pol-lution by asbestos (as amended) is to lay down measures for prevention and reduction of pollu-tion by asbestos and for protection of human health and the environment.

Member States must take the measures necessary to ensure that asbestos emissions into the air, asbestos discharges into the aquatic environment, and solid asbestos waste are, as far as reasonably practicable, reduced at source and prevented. In the case of the use of asbestos, these measures should entail using the best available technology not entailing excessive cost, including where appropriate recycling or treatment.

The Asbestos Directive (87/217/EC) requires Member States to take the measures necessary to ensure that:

in the course of the transport and deposition of waste containing asbestos fibres or dust, no such fibres or dust are released into the air and no liquids which may contain asbestos fi-bres are spilled,

where waste containing asbestos fibres or dust is landfilled at sites licensed for the purpose, such waste is so treated, packaged or covered, with account being taken of local conditions, that the release of asbestos particles into the environment is prevented.

Persistent organic pollutants

Persistant organic pollutants have particularly serious health and environmental properties. They remain intact in the environment for long periods, become widely distributed geographical-ly, accumulate in the fatty tissue of humans and wildlife, and have harmful impacts on human health or on the environment. The Stockholm Convention on Persistent Organic Pollutants, wchich was adopted in May 2001 ans entered into force in May 2004, is a global treaty to pro-tect human health and the environment from these chemicals. It was negotiated under the aus-pices of the United Nations Environment Programme (UNEP) and is building on the 1998 Aar-hus Protocol.

Regulation (EC) No 850/2004 on persistent organic pollutants (the POPs Regulation) is the main legal instrument for implementing the Stockholm in the EU legislation. As a Regulation, it is directly applicable in all Member States.

According to the Regulation, all remaining stockpiles consisting of or containing any POPs, for which no use is permitted, shall be managed as Hazardous waste. Holders of such stockpiles shall manage it in such a way that the POPs content is destroyed or irreversibly transformed. Producers and holders of waste are obliged to undertake measures to avoid contamination of waste with POPs substances.


According to Annex V of the POPs Regulation, the following disposal and recovery operations are permitted for these purposes:

D9: Physico-chemical treatment

D10: Incineration on land

R1: Use principally as a fuel or other means to generate energy under certain circumstances (excluding waste containing PCBs)

R4: Recycling/reclamation of metals and metal compounds (under multiple and strict re-strictions).

The Regulation also allows the permanent storage in safe, deep, underground, hard rock for-mations and salt mines or in landfill sites for hazardous waste, provided that the waste is solidi-fied or partly stabilised where technically feasible (for POPs waste under a certain limit level, specified in Annex V of the POPs Regulation). In this case it is to prove that the destruc-tion/transformation is not possible.

Pre-treatment operations prior to destruction or irreversible transformation may be performed, provided that the substances isolated from the waste during the pre-treatment subsequently are disposed of in accordance with the POPs Regulation.

In addition, repackaging and temporary storage operations may be performed prior to such pre-treatment or prior to destruction or irreversible transformation pursuant to the POPs Regulation.

The following Guidelines of the Basel Convention for POPs management must be considered as well:

General Technical Guidelines for the Environmentally Sound Management of Wastes Con-sisting of, Containing or Contaminated with Persistent Organic Pollutants (POPs) (SBC Nr. 2005/1)

Technical Guidelines for the Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Polychlorinated Biphenyls (PCBs), Polychlorinated Ter-phenyls (PCTs) or Polybrominated Biphenyls (PBBs) (SBC Nr 2005/2).

Waste from extractive industries

The European legislative framework for the safe management of waste from extractive indus-tries comprises of:

Directive 2006/21/EC on the management of waste from the extractive industries (the Mining Waste Directive);

Best Available Techniques reference document for the management of tailings and waste-rock in mining activities;

Amendment of the Seveso II Directive to include in its scope mineral processing of ores and, in particular, tailings ponds or dams used in connection with such mineral processing.

The Mining Waste Directive (2006/21/EC) introduces measures for safe management of waste resulting from the extraction, treatment and storage of mineral resources and the working of quarries. It lays down the rules for the granting of permits to operators of extractive industry waste facilities. The operators must provide a financial guarantee to ensure that the Directive’s obligations are covered prior to operations beginning. They must also ensure that funding is available for site restoration when a facility closes down. Operators must draw up a waste man-agement plan that prevents or reduces waste generation, and encourages waste recovery and safe waste disposal. It must be reviewed every 5 years by the authorities.


The authorities must inspect waste facilities at regular intervals, including after their closure. Operators are required to keep up-to-date records of all operations and to make them available for inspection by authorities.

Those wastes which result from prospecting, extraction, treatment and storage of mineral re-sources and the working of quarries and are covered by the Mining Waste Directive (2006/21/EC) are excluded from the scope of the Waste Framework Directive (2008/98/EC).

Mercury

Regulation (EC) No 1102/2008 sets provisions aiming in particular at reducing mercury supply and at ensuring a sound management of mercury waste. It provides mainly as follows:

The export from the Union of mercury and of several mercury compounds is prohibited (since March 2011)

Mercury that is no longer used in the Union in the chlor-alkali industry or that is gained from the cleaning of natural gas or from non-ferrous mining and smelting operations or that is ex-tracted from cinnabar ore qualifies as waste to be disposed of in accordance with the law of the Union on waste. Additionally, the companies involved in those activities must report to the competent authorities of the Member States and to the Commission information on the amount of mercury sent to temporary or permanent storage facilities.

Mercury as waste can be temporarily or permanently stored in underground and/or above-ground storage facilities, in accordance, inter alia, with the requirements set out in Directive 1999/31/EC on the landfill of waste, as amended by Council Directive 2011/97/EU.

2.2.3 EU Directives on Waste Treatments

Directive 1999/31/EC on landfill of waste

The objective of the Landfill Directive (1993/31/EC) is to prevent or reduce the adverse effects of the landfill of waste on the environment. It defines the different categories of waste (munici-pal, hazardous, non-hazardous waste and inert waste) to be landfilled and distinguishes three different classes of landfills:

Landfills for inert waste;

Landfills for non-hazardous waste;

Landfills for hazardous waste.

A standard waste acceptance procedure is laid down so as to avoid any risks3, namely:

Waste must be treated before being landfilled;

Hazardous waste must be assigned to a hazardous waste landfill;

Landfills for non-hazardous waste are foreseen for (pretreated) municipal waste and for in-dustrial and commercial non-hazardous waste;

Landfill sites for inert waste must be used only for inert waste.

3 Council Decision of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills

pursuant to Article 16 of and Annex II to Directive 1999/31/EC, OJ L 11, 16.1.2003.


The Directive sets up a system of permit conditions for landfill sites. Applications for permits must contain the following informations:

the identity of the applicant respectively of the operator and it’s financial security;

a description of the types and total quantity of waste to be landfilled;

the capacity of the disposal site and a description of the site;

the proposed methods for operation, monitoring and control plans, for pollution prevention and abatement measures;

the plan for closure and aftercare procedures;

an impact assessment study, where required under Directive 85/337/EEC4.

Member States must report to the Commission every 3 years on the implementation of the Di-rective.

The waste acceptance procedure and criteria are defined in Article 11 and Annex II to the Land-fills Directive and in Council Decision 2003/33/EC establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 and Annex II to Directive 1999/31/EC. The following wastes may not be accepted in a landfill:

liquid waste;

flammable waste;

explosive or oxidizing waste;

hospital and other clinical waste which is infectious;

used tires, with certain exceptions;

Any other waste which does not meet the acceptance criteria laid down in Annex II.

Council Decision 2003/33/EC5 provides for the criteria and procedures for the acceptance of waste at landfills, and in particular:

prescribes the procedure to determine the acceptability of waste at landfills as defined in Section 3 of Annex II to the Landfill Directive.

lays down the acceptance criteria for each landfill class as laid down in Section 2 of the An-nex to the Decision, and

lists the methods to be used for the sampling and testing of waste.

2.2.4 Waste related aspects of theIndustrial Emissions Directive

Directive 2010/75/EU on industrial emissions

The Directive 2010/75/EU on industrial emissions entered into force in January 2011. It is the result of the recast of the IPPC Directive6 (96/61/EC) and 6 other directives related to industrial emissions. These are:

the 3 directives on waste from TiO2 industry;

the Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations

4 Council Directive 85/337/EEC of 27 June 1985 on the assessment of the effects of certain public and private projects

on the environment (Environmental Impact Assessment Directive) 5 Council Decision 2003/33/EC establishing criteria and procedures for the acceptance of waste at landfills pursuant to

Article 16 of and Annex II to Directive 1999/31/EC 6 Directive 96/61/EC concerning integrated pollution prevention and control (IPPC Directive)


the Waste Incineration Directive(2000/76/EC)

the Directive 2001/80/EC on large combustion plants.

The Industrial Emissions Directive (2010/75/EU) aims to achieve a high level of protection of human health and the environment by reducing harmful industrial emissions, in particular through better application of Best Available Techniques (BAT).

The Industrial Emissions Directive improves and clarifies the concept of the BATs (Best Availa-ble Technology Concept). It also introduces minimum provisions on environmental inspections of installations, the review of permit granting conditions, and reporting of compliance with regu-lations.

Like the former IPPC Directive (2008/1/EC), the aim of the Indsutrial Emissions Directive (2010/75/EU) is to achieve a high level of environmental protection through the integrated permitting of certain highly polluting new or existing industrial and agricultural installations, the so-called "IED (former IPPC) installations". It covers a wide range of activities, i.e. from metals production, the processing of minerals, chemical manufacture, poultry and pig farming, to waste incineration and fuel combustion in large combustion plants. This permit can only be issued if the relevant environmental conditions are met, so that the companies themselves bear respon-sibility for preventing and reducing any pollution they may cause.

The Industrial Emissions Directive is based on four main principles:

the integrated approach, i.e. the permits must take into account the whole environmental performance of the plant,

the permit conditions including emission limit values must be based on the BATs, layed down in BAT notes for each type of installation,

Allowing the licensing national authorities certain flexibility, when determining permit condi-tions, taking into account the technical characteristics of the installation, its geographical lo-cation and the local environmental conditions.

the participation of the public in the decision making process, giving access to permit proce-dure in order to give comments, and access to a public register, which is intended to pro-vide environmental information on major industrial activities.

Waste incineration and co-incineration plants

With the adoption of the Directive 2010/75/EU on industrial emissionsa recast of the Waste In-cineration Directive (2000/76/EC) took place. The requirements to waste incineration and co-incineration are now given in Chapter IV (Articles 42 -55) of the Industrial Emissions Directive (2010/75/EU) . The technical requirements for installations using incineration or co-incineration are found in Annex VI.

The delivery and reception of waste, especiallyof hazardous waste, is regulated in detail. Prior to accepting hazardous waste, the operator has to have available information about the waste and to carry out a comprehensive reception procedure. High standard measurement techniques are required to monitor emissions to ensure compliance with the emission limit values. Opera-tors of waste incineration and co-incineration plants of a capacity of 2 tonnes or more per hour have to realize an annual report about the functioning and monitoring of the plant which has to be provided to the competent authority and to be made available to the public. In addition, the competent authority has to elaborate a list of incineration or co-incineration plants with a nomi-nal capacity of less than 2 tonnes per hour and has to make this list available to the public.


Landfills falling under the scope of the Industrial Emissions Directive (2010/75/EU).

Some landfills covered by Directive 1999/31/EC on Landfill of Waste also fall within the scope of the IED Directive (2010/75/EU). As a consequence, the requirements laid down in Annex I to the Landfills Directive replace the emission limit values, equivalent parameters and technical measures based on best available techniques (BAT) required by the Industrial Emissions Di-rective.

The Industiral Emissions Directive also requires competent authorities to periodically reconsider and, where necessary, update the permit conditions. This obligation is independent from pollu-tion levels, substantial changes in BAT, safety requirements or new legislative provisions. No corresponding provision exists in the Landfills Directive. Any landfill also covered by the IED must be made subject to such periodic reconsideration. Landfills covered by the IED must be made subject to public participation and information as outlined above.

2.2.5 Waste shipment Regulation

Regulation (EC) No 1013/2006 of 14 June 2006 on shipments of waste lays down procedures for the transboundary shipments of waste and implements the provisions of the Basel Conven-tion on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal as well as the Decision of the OECD Council on the control of transboundary movements of waste destined for recovery operations (OECD Decision). The Regulation which is directly applicable in the Member States was amended in 2014 by Regulation (EU) No 660/2014.

The Waste Shipment Regulation (Regulation (EC) No 1013/2006) includes a ban on the export of hazardous wastes to non-OECD countries ("Basel Ban") as well as a ban on the export of waste for disposal. It also stipulates a procedure of prior written notification and consent before cross borders shipments of all hazardous waste and some other types of waste, including cer-tain non-hazardous wastes that are destined to non-OECD countries.

The amendment of the Waste Shipment Regulation through Regulation (EU) No 660/2014 aims at better addressing of the problem of illegal waste shipments by strengthening Member States' inspection systems. Member States are required to establish inspection plans by 1 January 2017 based on a risk assessment that would aim, inter alia, to identify the minimum number of inspections required. Moreover, the amendment the Waste Shipment regulation aims to provide enhanced powers to the authorities involved in inspections, enabling them to decide on the ba-sis of evidence whether a carried substance or object is waste and whether a shipment can be considered an illegal shipment of waste.


2.2.6 European Agreement Concerning the International Carriage of Dangerous Goods (ADR)

The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) is under the auspices of the United Nations Economic Commission for Europe. The Agreement was amended by the Protocol amending article 14(3) and entered into force on 19 April 1985.

Equivalent agreements have been realized concerning the International Maritime Dangerous Goods Code (of the International Maritime Organization), the Technical Instructions for the Safe Transport of Dangerous Goods by Air (of the International Civil Aviation Organization) and the Regulations concerning the International Carriage of Dangerous Goods by Rail (of the Intergov-ernmental Organisation for International Carriage by Rail).

Apart from some excessively dangerous goods excluded from international carriage by road, other dangerous goods may be carried internationally in road vehicles subject to compliance with the conditions laid down in:

Annex A of the ADR for the goods in question, in particular as regards their packaging and labelling; and

Annex B of the ADR, in particular as regards the construction, equipment and operation of the vehicle carrying the goods in question.

Annexes A and B were entirely revised and restructured between 1992 and 2000, and a first version of the restructured annexes entered into force on 1 July 2001. A set of new Amend-ments entered into force in 2003 and 2005. The new structure is consistent with that of the Unit-ed Nations Recommendations on the Transport of Dangerous Goods, Model Regulations.

Despite the fact that the EU is not a signatory Party and has not joined the European Agree-ment concerning the International Carriage of Dangerous Goods by Road (ADR), at EU level it is implemented through Directive 94/55/EC on the approximation of the laws of the Member States with regard to the transport of dangerous goods by road, as amended by Directive 2000/61/EC, Decision 2002/886/EC, Directive 2003/28/EC and Directive 2006/89/EC.

If hazardous waste streams are dangerous goods in the sense of ADR has to be decided in every single case, depending of the quantity and concentration of dangerous substances in the transport unit. Most of other hazardous substances which may arise in hazardous waste streams are not covered by the ADR agreement.

Examples of cases where the ADR regulations may apply are:

Asbestos based insulation material (EWL code 17 06 01*) – UN 2590 or UN 2212, class 9.

PCB containing Construction&Demolition waste (EWL code 17 09 02* ) – UN 3152, class 9.

Wastes containing mercury – UN 2809, class 8, UN 2825, class 6.1.

Residues of paint and lacquer – UN 1263, class 3; UN 3066, class 8.

For these materials a proper packaging and labelling in accordance with the ADR agreement is mandatory. Packaging and labelling has to be done at the place of generation.


3 ORGANISATION OF WASTE MANAGEMENT, INCLUDING DIVISION OF RESPONSIBILITIES BETWEEN PUBLIC AND PRIVATE SECTOR IN THE AREA OF HAZARDOUS WASTE MANAGEMENT

According to article 17 of the law on waste management authorities and entities responsible for waste management are the following:

Government of the Republic of Serbia;

Government of the Autonomous Province;

Local self-government units (municipalities);

Environment Protection Agency;

Officially approved professional organizations for waste testing;

Non-governmental organizations, including consumers’ organizations;

Other authorities, organizations and private waste owners, in compliance with law

In articles 18 – 22 of the Serbian Waste Management Act the competences for waste manage-ment of the Ministry for Agriculture and Environmental Protection (MAEP), of the Autonomous Province (AP), of the Local self-government units (LSG) and of the Serbian Environmental Pro-tection Agency (SEPA) are described in detail. art. Article 23 describes competences of Professional Organizations for Waste Testing. Article 46 comprises regulations on the document of movement of hazardous waste and on related competent authorities. The competences for permitting are laid downn article 60 and the competences for inspections in article 84.

In the following table the essential regulations on competences in waste management in Serbia are presented, distinguishing between hazardous waste (HW), inert waste (IW) and municipal, commercial or industrial non-hazardous waste (NHW). For details please refer to the Waste Management Act.

Table 1: Competences in waste management in Serbia.

MAEP AP LSG SEPA

Permits for collection, transport, storage, treatment, recovery7, disposal

HW

IW, NHW if operating in more than one LSG

IW, NHW in case of incin‐eration

All kind of waste treated in mobile facil‐ities

All kind of waste if oper‐ating within AP only

City of Bel‐grade: All kind of waste, if con‐struction per‐mit was issued by City of Bel‐grade1

Other LSG: IW, NHW

none

7 new provision in the draft for an amendment of the law on waste management (30.11.2015)


MAEP AP LSG SEPA

Information on issued permits

Own permits;

Only own permits

Only own permits

Register of all permits through in‐formation from all per‐mitting au‐thorities

Information on waste quantities and types

None None none Waste data base (receives in‐formation from all waste generators and owners)

Information on move‐ment of hazardous waste (inside the coun‐try)

since 2015: None

Before: Yes

Yes City of Bel‐grade: Yes1

Others: none

since 2015: Yes

before: None

Inspection of installa‐tions

HW

IW, NHW if operating in more than one LSG

HW

IW, NHW if operating in more than one LSG inside of AP

IW, NHW none

Notification of trans‐boundaryshipment of waste (ex‐port/import/transit)

Yes None None None

Information on the transboundary ship‐ment of waste (ex‐port/import/transit)

Yes None None Yes

National Strategy

Responsible in cooperation with AP

Participation Participation None

National, regional and local waste manage‐ment planning

National Plan, in cooperation with AP2

Consent to re‐gional plans others than AP

Cooperation in National Plan2

Regional plan

Consent to re‐gional plans others than AP

Plans for cer‐

Participation in regional plans, if comprising more than 1 LSG

Local Plan

None


MAEP AP LSG SEPA

tain waste streams of im‐portance for AP2

Prevention Waste preven‐tion pro‐gramme

‐ ‐ ‐

1 As of 1.3.2016.

3.1 Republic of Serbia / Ministry of Agriculture and Environmental Protection

The Ministry of Agriculture and Environmental Protection is organized in two branches

agriculture and

environmental protection.

The branch of environmental protection is organized in three sectors.

The Sector of Environmental Protection is responsible for strategies in the field of nature protection, biodiversity, sustainable use of resources, water quality as well as international cooperation in these fields

The Sector of Planning and Management in the Environment is responsible for environ-mental policy related to cleaner production and sustainable development (e.g. EMAS), envi-ronmental impact assessment, safety reports and emergency plans of SEVESO-installations. This sector is also responsible for waste management, chemicals and pesti-cides.

The Inspection Sector for Environmental Protection is performing activities related to prevention and control of environmental pollution and chemical products; the sector is also responsible for the control of waste treatment installations.

3.1.1 Sector on Planning and Management in the Environment

This sector includes a waste management department with separate divisions for issuing per-mits, developing systems for waste management and authorizing transboundary movements of wastes.

Department for Waste Management

The division for transboundary movement of wastes functions as the Competent Authority (CA) under the Basel Convention and is responsible for the granting of export-, import- and transit-notifications for the shipment of wastes.

The division for developing the systems for waste management is responsible i. a. for prepara-tion of by-laws for the sound management of specific waste streams, for the up-date of waste related strategies and the development of standards for waste treatment.


The division for issuing waste management permits acts as permitting authority for waste relat-ed activities (collection, storage, transport, treatment and disposal) for hazardous wastes and non-hazardous wastes within the competence of the Serbian Government.

3.1.2 Sector on Environmental Inspections

The Environmental Inspection (EI) is organized in seven specific departments. One of them is the Control Department for waste management.

Department for Waste Management

This department for waste management performs inspections of waste treatment installations for hazardous wastes and specific other waste streams (i. a. packaging wastes) and general in-spections to determine the compliance with environmental requirements.

The department is the competent authority for the export, import and transit of wastes and co-operates with international networks in this field (IMPEL8, ECENA9). It performs inspections and joint inspections to prevent illegal movements of regulated wastes.

3.2 Environment Protection Agency – SEPA

SEPA performs professional tasks related to:

The management of the national information system for environmental protection (through environmental indicators, the registry of pollutants, etc.);

The implementation of monitoring systems for the control of air quality, surface water and groundwater aquifer and precipitation;

The management of the National Laboratory;

The preparation of reports on the state of the environment and implementation of environ-mental policy;

Keeping data on best available techniques and and their implementation as well as other ac-tivities specified by law.

The Department of the National Register for Pollution Sources bears the main responsibility of issues related to wste.

Responsibilities of SEPA in the field of waste management:

Maintenance of the database on waste management within the environmental information system, mentioned above;

Maintenance of data on quantities of waste, including secondary raw materials

Reporting on waste management, in compliance with the assumed international obligations.

The collection of all permits from the ministry and the municipalities, including Autonomous Province of Vojvodina.

The establishment and maintenance of a register of PCB-containing devices in use (see Arti-cle 52 of the Waste Management Act).

8 European Union Network for the Implementation an Enforcement of Environmental Law 9 Environmental Compliance and Enforcement Network for Accession


The databases and reports on waste quantities are feeded by numerous reporting obligations of waste owners like mentioned as follows:

As laid down in the Waste Management Act, entities who perform collection, storing and treatment of used batteries and accumulators, waste oils, waste tires, waste of elec-tric and electronic products, waste mercury-containing fluorescent tubes and PCB waste shall hold a permit, maintain and keep records on these waste streams and on quan-tities collected, stored or treated, and shall submit those data to SEPA (see Articles 47 to 52 of the Waste Management Act).

Owner of asbestos-containing waste shall maintain records on quantities of waste stored or disposed of and shall submit such data to SEPA (Article 54 of the Waste Management Act).

The entity that treats end-of-life vehicles shall maintain records on all the phases of treatment, and shall submit such data to SEPA (Article 55 of the Waste Management Act).

Pharmacies and healthcare institutions shall maintain and keep records on pharmaceuti-cal waste and shall submit such data to SEPA (Article 56 of the Waste Management Act).

Generator and owner of waste from Titanium Dioxide Industry shall hold appropriate permit, maintain and keep records on quantities of this type of waste collected, stored, treated or disposed, and shall submit such data to SEPA (Article 57 of the Waste Management Act).

Every waste generator and owner, except for households, shall maintain and keep daily records on waste and shall submit regular annual report to SEPA.

Local self-government units shall maintain and keep records on collected municipal waste, as well as list of unregulated landfills and shall submit such data to SEPA (Article 75 of the Waste Management Act).

Concerning products that become special waste streams upon use thereof an annual re-port as well as daily records on the amount and type of produced and imported products shall be kept by charge payers and shall be submitted to SEPA. The products that become spe-cial waste streams upon use thereof includes tyres, products containing asbestos, batteries and accumulators, any mineral or synthetic oil and lubricant, end-of-life vehicles as well as electrical and electronic products (see Decree No. 54/201010).

3.3 Republic Statistical Office

The Statistical Office is:

Responsible for the reporting to Eurostat in accordance with the Waste Statistic Regulation.

Coordinator of official statistic data in Serbia.

Users of the Office’s data and services encompass citizens, legal entities, state administration bodies and local self‐ government bodies, journalists, scientists, researchers, analytics, stu‐dents and international organizations.

Waste related responsibilities

The Unit for Environment Statistics within the Department for Business Statistics of the Republic Statistical Office produces statistical data of importance for presentation of environmental status in the area of waste, hazardous chemicals and water-related statistics. Preparation and imple-mentation of research conducted in the area of waste statistics includes, in addition to the

10 Decree No. 54/2010, the decree on products that become special waste streams upon use

thereof.


Group for environmental statistics of the Republic Statistical Office, the Sector for statistics of the AP Vojvodina and local organisational units of the Statistical Office and secretariat for ad-ministration - Statistical sector, the City of Belgrade.

The method applied for the collection of data on waste is a survey through a questionnaire. Re-porting units are commercially active companies with nine or more employees. The received da-ta is used for reporting to Eurostat pursuant to the Waste Statistic Regulation. The reports are composed every second year, and starting from 2012 data has been submitted regularly.

3.4 Expert Waste testing organization

Waste testing shall be performed by professional organizations and other legal entities author-ized for sampling and characterization according to the volume of testing for which they have been accredited, in compliance with law.

Such laboratories performing waste testing apply for certification at the Environment Ministry every four years; prerequisite for the certification is that the Laboratories are accredited by the National Accreditation Body. The Accreditation Audit is repeated every year.


According to Article 23 of the Law on WM, waste testing shall be performed for waste classifica-tion for the following activities:

Transboundary movement;

waste treatment; and

waste disposal.

Waste characterization shall be performed for hazardous waste only, and for the waste which according to its origin, composition and properties may be hazardous waste, except for house-hold waste.

3.5 Autonomous Province Vojvodina

The Law on Establishing Competencies of Autonomous Province of Vojvodina (RS No. 99/09) sets out the competences of the Autonomous Province. The Autonomous Province of Vojvodina has its own revenues to be used to finance its competences (Article 8 of the Law RS No. 99/09).

Article 25 of the Law on Establishing Competencies of Autonomous Province of is setting the specific responsibilities for environmental protection. This gives Autonomous Province of Vojvo-dina a wide responsibility for the implementation of the environmental acquis. The administra-tion of the autonomous province of Vojvodina has 11 secretariats; one entitled Provincial Secre-tariat for Urban Planning, Construction and Environmental Protection also performing issues on waste management.


Pursuant to Article 18 of the Law on WM the responsibilities of the Autonomous Province of Vojvodina are prescribed as following:

participate in the development of the strategy and specific national waste management plans;

coordinate and perform waste management activities of importance for the Autonomous Province, and monitor the status;

give consent to regional waste management plans at its territory;


issue permits, approvals, certificates and other acts in compliance with this Law, maintain the records and submit data to the Ministry;

supervise and control measures of waste management at its territory in compliance with this Law and perform other activities prescribed by law.

The Autonomous province is entrusted with issuance of permits for collection, transport, stor-age, treatment and disposal of waste for all the activities at the territory of autonomous province and for all the facilities that apply for construction permit at the competent authority of autono-mous province (see Article 60 of the LWM).

Implementation of regional waste management plans, as well as construction of facilities for storage, treatment and disposal of waste in the area of competence of autonomous province shall be financed from earmarked funds of the autonomous province budget, loans, donations and funds of legal and private entities who manage waste, charges and other sources of financ-ing, in compliance with law (see Article 80 of the LWM).

The Autonomous province shall be entrusted with inspection over the activities related to waste management which are completely performed at the territory of autonomous province and over the operation of waste management facilities permitted by autonomous province on the basis of this Law (see Article 84 of the LWM).

Most of the local self-government units (municipalities) at the territory of the Autonomous Prov-ince of Vojvodina have established joint local self-government units, but did not establish a regional waste management plan.

3.6 The local self-government unit

Article 18 of the Law on Local Self-Government (OG of the RS No. 129/2007, last amended in 2010) establishes the Municipality as the basic territorial unit of local self-government.

A key competence of the LSG units is set in Article 20 (5). It is under this Article of the Law that responsibilities are placed on the LSG units in relation to the Drinking Water Directive (98/83/EC), the Urban Waste Water Treatment Directive (91/271/EEC) and the Waste Frame-work Directive (2008/98/EC).

Waste management related responsibilities

According to Article 20 of the LWM, the local self-government unit:

shall adopt the local waste management plan, provide conditions and ensure its implemen-tation;

shall prescribe, ensure, organize and perform the management of municipal waste, which is inert and non-hazardous waste, on its territory;

shall prescribe the procedure of service charging in the area of municipal waste manage-ment;

shall issue permits, approvals and other acts in accordance with the law, shall keep a rec-ord and submit data to the Ministry;

on request of the Ministry and the competent authority of the autonomous province shall pro-vide opinion during permit issuance procedure;

shall supervise and control waste handling measures and performs other activities pre-scribed by the law.


In addition, Article 97 of the LWM stipulates that local self-government unit shall:

develop a list of unregulated waste disposal sites at its territory which do not meet re-quirements proscribed by this Law;

develop projects of rehabilitation and re-cultivation of unregulated landfills, which shall be approved by the Ministry, i.e. the autonomous province.

determine location for the construction and operation of the facility for storing, treatment or disposal of waste at its territory.

The local self-government unit shall, within an act, establish the authorities and departments competent for performing the activities referred to in above. The local waste management plan shall be prepared by a division within the local authorities within the local self-government unit that is responsible for waste management (see Article 13 of the LWM).

Hazardous waste from households (used batteries, waste oils, paints and varnishes, pesti-cides, etc.) shall be delivered to a point designated for selective collection of hazardous waste or to legal entity authorised for collection of hazardous waste, both to be permitted by the minis-try (see Article 43 of the LWM). The local self-governments unit shall provide for collection and delivery of end-of-vehicles to the entity permitted to treat such vehicles if the owner is unknown (see Article 55 of the LWM).

Permits for storage, treatment and disposal of inert and non-hazardous waste at the territories of more than local self-government unit are issued by the Ministry, i.e. competent authority of autonomous province for the territory of autonomous province.

3.7 Joint waste management of local self-government units

Local self government units are in charge of hazardous waste generated by households.

According to Article 21 of the Serbian Waste Management Act, a joint waste management via an assembly of two or more local self-government units can be established:

Two or more local self-government units may jointly provide and carry out waste manage-ment, if such is their mutual interest, under the conditions determined by law and by an agreement signed among the assemblies of local self-government units.

The above agreement shall regulate mutual rights and duties in providing conditions for per-forming the activity as well as for waste management facility operation on the territory of those self-government units. The agreement regulates decision-making procedure in case of disagreement among local self-government units as well as other issues relevant to or-ganizing and carrying out waste management.

Assemblies of two or more local self-government units with at least 250,000 inhabitants living within their territories shall develop a regional waste management plan, which shall define common goals in waste management, in compliance with the Serbian Waste Management Strategy (see Article 12 of the Waste Management Act).


3.8 Standing conference of towns and municipalities

The “Standing Conference of Towns and Municipalities (SCTM)” is the association of Serbian towns and municipalities. The SCTM is supporting the towns and municipalities via building up competences and staff resources to be in line with overall Serbian legislation requirements. The SCTM plays an important role in terms of organising the information exchange to foster the communication between their Members and other institutions.

Committee for Environmental Protection

Several Committees have been established; the committee for Environmental Protection is also dealing with issues of waste management. The aim of one of the projects is to work intensively on planning and strategy in the field of waste management and waste water at municipality lev-el.

One of the initiatives started by the SCTM was for mapping local strategic documents in order to enable, prioritize and coordinate their activities at the local level, and to enhance and facilitate the implementation of local strategic plans. This initiative is to be extended to strategical plan-ning on waste management at local and city level.

3.9 Ministry of Labour, Employment, Veteran and Social Affairs

The Labour Inspectorate as an administrative body within the Ministry of Labor, Employment, and Social Issues, performs inspection activities and associated professional activities in the field of labor relations and occupational safety and health at work. This means:

regular monitoring and control;

investigation of deaths, collective and serious injuries at work;

determining the fulfillment of conditions in the field of safety and health at work before the commencement of operations of the employer, as well as other activities specified by law.

The labour inspections

The Labour Inspectorate is a relevant stakeholder with regard to collection and treatment of waste, especially hazardous waste. The labour inspectors carry out inspections on occupational safety on the whole territory of Serbia including the Autonomous Province. The Companies to be inspected include all types of sectors including the waste management sector. They prove, if the minimum requirements on occupational safety which are laid down in the respective Law and Rulebooks are met. Two rulebooks for Asbestos and Chemicals seem to be especially rele-vant for hazardous waste management. In the past one of the main issues in the waste man-agement sector for labour inspectors has been the asbestos management and the occupational safety at de-construction sites.

Joint Inspections

A Working Group on Joint Inspections has been established under the Frame of the Law on In-spections and with the participation of the Ministry of Environment and the Ministry of Labour. Joint inspections could facilitate the information exchange between the Inspectorates e. g. con-cerning the handling of hazardous waste by the operators.


3.10 Private sector participation

Significance of private sector in the context of extended producer responsibility

Producers, importers, distributors and sellers of products are influencing by their economic ac-tivities the composition and technical characteristics of the sold products; they determine the life cycle of the products and decide on the use of the hazardous substances in the products and during the production and distribution process. Hence producers, importers, distributors and sellers of products decide decisively about the hazardous character of waste, the increase of waste volume and the resulting environmental problems connected with. As consequence pro-ducers, importers, distributors and sellers of products have to be made responsible for the man-agement of these end-of-life products and the related costs.

Article 25 of the Waste Management Act imposes provisions on extended producer responsibil-ity. Extended producer responsibility is imposed on all manufacturers/importers whose products become hazardous waste. Responsibility means also to bear the costs for their treatment and disposal. Main principle in all environmental purposes is the polluter pays principle which means that polluters must bear full costs of the consequences of their activities. The costs of genera-tion, treatment and disposal of waste from end-of life products must be included in the price of a product.

Article 27 of the Waste Management Act makes it clear that the owner of waste is responsible for all waste management obligations and costs. Also any manufacturer or importer whose product enters the country becomes waste owner in the legal sense. Therefore they are also obliged to cover fees for the management of these “end-of-life products” under certain condi-tions. Producer responsibility is imposed by the Decree on specific waste streams, such as packaging waste, WEEE, end-of-life vehicles and waste batteries and accumulators.

Significance of private sector in the context of establishing waste prevention programs (Article 29 of the Waste Management Act)

Waste prevention is a key factor in any waste management strategy. Waste prevention means reducing the amount of waste generated and reducing its hazardousness by reducing the pres-ence of dangerous substances in products.

Waste prevention programs enter deeply into producer’s know-how and responsibility. It is therefore indispensable to develop such programs in close cooperation between the Ministry and the private sector. However, at present waste prevention programs have not yet been es-tablished in Serbia. The new Article 11a to the amended Waste Management Act provides the legal basis for the establishment of waste prevention programs, according to the responsibilities of the Ministry of the Agriculture and Environmental Protection. A draft Regulation on the list of measures of prevention of waste will transpose Annex IV of the Waste Framework Directive.

Such activities are expected to enable important impulses to industrial innovation and create new and high standing employment, hence a contribution to the development of “green econo-my”.

Significance of private sector in waste collection, transport, treatment and disposal activ-ities

Participation of the private sector in waste management activities like collection, transport, treatment and disposal is of a high priority for the Government of the Republic of Serbia. In or-der to develop competition between the public and the private sector, the Government needs to take necessary organizational measures and actions.

Private entities might prove to be able to provide the services of collection, transportation, treatment and disposal of waste more efficiently, and with lower costs than the public sector


does. This competitive scheme should be possible for commercial, non-hazardous waste and for hazardous waste as well. Concerning municipal waste, the competent authorities should de-cide, if it is wise to transfer the public know-how of municipalities in municipal waste manage-ment completely to the private sector.

Private commercial entities can especially be interested in providing services of managing spe-cific waste streams. Bearing in mind the elevated competences of commercial sectors and in-dustrial branches over certain waste streams (medical waste, mining waste, waste oil, mineral raw materials, pesticides etc.), maximum cooperation between the competent authorities and the private sector should be aspired, in order to manage these individual waste streams ade-quately. Private sector can also be privileged partner in introducing innovating technologies in waste management.

However, the inclusion of private sector in waste management does not guarantee the efficiency per se. It shall be necessary to stipulate competitive tenders for provision of services. This needs efficient supervision of the contracts and the provision of services by public entities. It shall be necessary to introduce incentive measures for the participation of the private sector in all domains suitable for private engagement and to work on the development of partnerships be-tween the public and the private sector. The private sector participation may have several ad-vantages: provision of investment capital, decrease of needs for subsidies, improvement of management effectiveness, improvement of technical and management capacities.

Serbian Law on Waste Management has established liabilities and obligations for all parties par-ticipating in waste management: waste generators, i.e. waste owners, waste collection and transport operators and plants operators for storage, treatment and landfill facilities.

Significance of the private sector in data submission

The Document on waste movement (for non-hazardous and inert waste), the Document оn haz-ardous waste movement and the annual reports extracted from these data are crucial for future waste management planning. Their submission from private waste owners to responsible enti-ties enables not only the tracking (and control) of the movements of privately owned wastes, but also creates the basis for numerous other waste management purposes.

In case of hazardous waste movement, the hazardous waste generator (and/or owner), the op-erator (and/or owner) of the plant for treatment or disposal and as third party the transport firm are concerned. It is of high interest that all parties concerned are motivated and willing to deliver high quality data.

Significance of the private sector in public awareness raising

Public awareness raising campaigns encourage individual consumers to assist in achieving a sustainable waste management through decreasing waste generation, purchase of products made of recyclable materials, separation of waste for recycling and participation in local work-shops on waste management. These initiatives areaiming at encouraging population to assume a more responsible attitude towards waste and to handle waste in a sustainable manner, includ-ing a waste reduction at the source, reuse of waste, recycling or reliable waste disposal if there is no other possibility. Public entities, but also private companies dealing with waste should in-clude in their activities campaigns for raising public awareness for waste management issues. It will help the responsible entities to manage the waste in an atmosphere of consensus with the majority of the population.


4 CURRENT STATUS OF THE WASTE MANAGEMENT REGARDING HAZARDOUS WASTE

4.1 Qualitative Characterization of hazardous waste

4.1.1 Waste sources of hazardous waste

The Waste Framework Directive (2008/98/EC) defines ‘hazardous waste’ as ‘waste which displays one or more of the hazardous properties listed in Annex III of WFD”. I’. The classification of waste as hazardous is further specified by the Decision 2000/532/EC establishing a List of Wastes.

In accordance with the Waste Management Act11 hazardous waste means “waste that according to its origins, composition or concentration of hazardous substances may cause danger to the envi-ronment or human health and has at least one of dangerous chracteristics determined by special regulation”. Wastes are classified in Serbia in accordance with the Regulation on categories, test-ing and classification of waste12. The regulation is implementing inter alia the European List of Wastes.

Although the share of hazardous wastes in total waste generation is relatively low, the generation of hazardous waste deserves a special attention due to the potential negative health and environ-mental affects that hazardous waste may lead to.

Hazardous wastes arise practically in all economic activities. In general, the following main sources of hazardous waste can be distinguished:

industry:

e.g. acids, bases and spent solvents from chemical industry, sludges and filter cakes from

gas treatment in metal industry, hazardous slags and ashes from co-incineration,

services and commerce:

e.g.WEEE, used oils, batteries and accumulators from services and commerce

construction sector:

e.g contaminated soils, asbestos wastes

waste treatment sector:

e.g. slags and ashes from waste incineration, sludges from physico/chemical treatment

health sector:

e.g. infectious waste, chemicals, cytotoxic wastes, amalgam

households:

e.g. WEEE, batteries and accumulators, waste oils, paints

The generation of industrial hazardous waste depends of course strongly on the economic struc-ture. The hazardous waste generation from waste treatment activities depends on the level of the waste treatment infrastructure, e.g. waste incineration and chemical-physical leads to secondary hazardous waste generation.

In Serbia, the most relevant quantities of hazardous waste have been reported in the sector “min-ing and quarrying” and in the manufacturing industry.

11 Official Gazette of the Rupublic of Serbia, No. 36/09 as amendetd 12 Official Gazette of the Republic of Serbia, No 56/10


4.1.2 Composition of hazardous waste

The following table presents an overview of the 15 properties which render waste hazardous as laid down in Annex III of the Waste Framework Directive 2008/98/EC. In Annex III of the Waste Framework Directive the hazardous properties are further specified and broken down to hazard classes and categories which in turn are assigned to hazard statement codes. In some cases haz-ardous properties of waste are assessed based on the properties and concentrations of the haz-ardous substances contained in the waste.

Table 2: Properties of waste which render it hazardous according to AnnexIII of the Waste Framework

Directive 2008/98/EC.

Hazardous properties

HP1 Explosive

HP2 Oxidising

HP3 Flammable

HP4 Irritant – skin irritation and eye damage

HP5 Specific Target Organ Toxicity (STOT)/

Aspiration Toxicity

HP6 Acute Toxicity

HP7 Carcinogenic

HP8 Corrosive

HP9 Infectious

HP10 Toxic for reproduction

Based on a substance-oriented approach, the following main categories for hazardous wastes can be distinguished (EWC-Stat-classification):

Spent solvents

Acid, alkaline or saline wastes

Used oils

Chemical wastes

Industrial effluent sludges

Sludges and liquid wastes from waste treatment

Health care and biological wastes

contaminated glass wastes

contaminated wood wastes

Waste containing PCB

Discarded equipment (excluding discarded vehicles, batteries and accumulators wastes)

Discarded vehicles

Batteries and accumulators wastes

Mixed and undifferentiated materials

Sorting residues


Mineral waste from construction and demolition

Other mineral wastes

Combustion wastes

contaminated Soils

contaminated Dredging spoils

Mineral wastes from waste treatment and stabilised wastes

4.1.3 Overview on waste codes for hazardous wastes

The European List of Waste (LoW) serves as a common encoding of waste characteristics in a broad variety of purposes including classification of hazardous wastes. Any entry of the List of Waste marked with an asterisk (*) shall be considered as hazardous. All other entries are consid-ered non-hazardous.

The List of Waste includes „absolute hazardous entries“and so-called „mirror entries“ for hazardous wastes. Wastes which are assigned to „absolute hazardous entries“ cannot be allocated to alterna-tive entries and are hazardous without any further assessment. „Mirror entries“are entries, where similar waste from the same source might be allocated to a hazardous entry or to a non-hazardous entry depending on the specific case, on the composition and on the specific properties of the waste. If the composition of the waste is unclear, if the waste displays one or more of the 15 haz-ardous properties or it if the content of specific POPs in the waste exceed the relevant limit values, the waste has to be classified as hazardous waste.

The European list of waste is structured on the first level by origin of wastes. Since hazardous waste may arise practically in all economic activities, all chapters of the List of waste contain en-tries for hazardous wastes.

The following chapters of the European list of waste are attributed to wastes from agriculture and forestry and to industrial and commercial wastes:

02 Wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing, food prepara-tion and processing

03 Wastes from wood processing and the production of panels and furniture, pulp, paper and cardboard

04 Wastes from the leather, fur and textile industries

05 Wastes from petroleum refining, natural gas purification and pyrolytic treatment of coal

06 Wastes from inorganic chemical processes

07 Wastes from organic chemical processes

08 Wastes from the manufacture, formulation, supply and use (MFSU) of coatings (paints, var-nishes and vitreous enamels), adhesives, sealants and printing inks

09 Wastes from the photographic industry

10 Wastes from thermal processes

11 Wastes from chemical surface treatment and coating of metals and other materials; non-ferrous hydro-metallurgy

12 Wastes from shaping and physical and mechanical surface treatment of metals and plastics

13 Oil wastes and wastes of liquid fuels (except edible oils, 05 and 12)

14 Waste organic solvents, refrigerants and propellants (except 07 and 08)


Separate chapters exist for:

waste from the Construction sector (Chapter 17 “Construction and demolition wastes” (including excavated soil from contaminated sites)),

medical waste (Chapter 18 “Wastes from human or animal health care and/or related research”

waste resulting from waste (and water) treatment (Chapter 19 “Wastes from waste management facilities, off-site waste water treatment plants and the preparation of water intended for human consumption and water for industrial use)

waste from households and similar commercial, industrial and institutional wastes (Chapter 20)

Wastes from mining and quarrying are covered by chapter 01 “Wastes resulting from exploration, mining, quarrying, physical and chemical treatment of minerals”. The Mining Waste Directive sets up the framework for proper management of wastes resulting from extractive industries and the wastes covered by the Mining Waste Directive are excluded from the scope of the Waste Frame-work Directive. However, the hazardousness of wastes from the extractive industries should always be classified in line with the List-of-Waste.

An own chapter is dedicated to waste packaging; absorbents, wiping cloths, filter materials and protective clothing not otherwise specified (Chapter 15), which may arise practically in all economic activities.

Chapter 16 “Wastes not otherwise specified in the list” comprises several important hazardous waste types, including end-of-life vehicles, WEEE and batteries and accumulators.

4.2 Quantitative Characterization of hazardous waste

Two main data sources for generation of hazardous waste in Serbia are available which are based on different legal reporting obligations: 1) Data according to surveys conducted by the Serbian Sta-tistical Office and 2) data of the Serbian Environmental Protection Agency (SEPA). The main re-sults from both of these data sources are presented in the following description of the status quo of the generation and treatment of hazardous wastes in Serbia. The summarizing illustration of the generation and treatment of hazardous wastes in Serbia is based solely on the data of Serbian En-vironmental Protection Agency.


4.2.1 Quantities of hazardous wastes generated in Serbia

According to SEPA, the total generation of industrial and commercial waste in Serbia in 2014 was 5.9 Mio tonnes, of which 210,000 tonnes was classified as hazardous waste. In addition, 2,13 Mio tonnes of municipal waste was generated in Serbia in 2014. The share of hazardous wastes in mu-nicipal waste is unknown. (MAEP 2014).

The following presents the generated quantities of hazardous industrial and commercial waste in 2014 broken down by the 2-digit chapter codes of the List-of-Waste. It needs to be noted, that the data includes 155,044 t of wastes from mining and quarrying, which as of the reference year 2015 are not anymore included in the SEPA-statistics on hazardous waste generation, since it is regarded that these wastes are not covered by the Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

The data on the generation of hazardous industrial and commercial waste covers quantities report-ed by companies which submit to the Environmental Protection Agency annual reports13 on the types and quantities of waste generated in the course of their business activities. The data does not include quantities of these types of waste generated by households and disposed of on wild dumpsites or delivered directly to operators for treatment.

13 Every waste generator, except for households, shall maintain and keep daily records on waste and shall submit regular

annual report to SEPA, including the types and quanties of wastes generated.


Table 3: Quantities of hazardous industrial and commercial waste in Serbia in 2014 broken down by the 2-digit

chapter codes of the List-of-Waste (MAEP 2015).

Code Chapter Hazardous waste (t)

01 Wastes resulting from exploration, mining, quarrying, physical and chemical treatment of minerals

155,044

02 Wastes from agriculture, horticulture, aquaculture, forestry, hunting and fish-ing, food preparation and processing

2

05 Wastes from petroleum refining, natural gas purification and pyrolytic treat-ment of coal

5,537

06 Wastes from inorganic chemical processes 120

07 Wastes from organic chemical processes 1,421

08 Wastes from the manufacture, formulation, supply and use (MFSU) of coat-ings (paints, varnishes and vitreous enamels), adhesives, sealants and printing inks

1,956

09 Wastes from the photographic industry 1,038

10 Wastes from thermal processes 10,508

11 Wastes from chemical surface treatment and coating of metals and other materials; non-ferrous hydro- metallurgy

436

12 Wastes from shaping and physical and mechanical surface treatment of metals and plastics

909

13 Oil wastes and wastes of liquid fuels (except edible oils, 05 and 12) 11,962

14 Waste organic solvents, refrigerants and propellants (except 07 and 08) 88

15 Waste packaging; absorbents, wiping cloths, filter materials and protective clothing not otherwise specified

1,428

16 Wastes not otherwise specified in the list 11,690

17 Construction and demolition wastes (including excavated soil from contami-nated sites)

2,299

18 Wastes from human or animal health care and/or related research (except kitchen and restaurant wastes not arising from immediate health care)

2,682

19 Wastes from waste management facilities, off-site waste water treatment plants and the preparation of water intended for human consumption and water for industrial use

1,277

20 Municipal wastes (household waste and similar commercial, industrial and institutional wastes) including separately collected fractions

1,479

TOTAL 209,877

* Wastes from mining and quarrying, which as of the reference year 2015 are not anymore included in the

SEPA-statistics on hazardous waste generation, since it is regarded that these wastes are not covered by the

Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

The following table presents the generated quantities for 15 waste types, which together make up more about 90 % of the total amount of industrial and commercial hazardous waste generated in 2014 in Serbia.(SEPA 2015)


Table 4: Hazardous industrial and commercial waste in Serbia in 2014, the most important waste types (SEPA

2015).

Code Waste Hazardous waste (t)

01 04 07* Wastes containing hazardous substances from physical and chem-ical processing of non-metalliferous minerals

155,044

10 02 07* Solid wastes from gas treatment containing hazardous substances 6,370

10 02 13* Sludges and filter cakes from gas treatment containing hazardous substances

4,099

16 03 03* Inorganic wastes containing hazardous substances 3,222

05 01 06* Oily sludges from maintenance operations of the plant or equip-ment

2,975

13 01 05* Non-chlorinated emulsions 2,940

05 01 03* Tank bottom sludges 2,555

13 01 11* Synthetic hydraulic oils 2,294

16 07 08* Wastes containing oil 2,096

13 05 06* Oil from oil/water separators 2,055

16 01 07* Oil filters 1,923

17 05 03* Soil and stones containing dangerous substances 1,812

12 01 09* Machining emulsions and solutions free of halogens 1,385

16 02 15* Hazardous components removed from discarded equipment 1,229

16 01 04* End-of-life vehicles 1,197

Other waste types 18,680

Total 209,877

* Wastes from mining and quarrying, which as of the reference year 2015 are not anymore included in the SEPA-statistics

on hazardous waste generation, since it is regarded that these wastes are not covered by the Waste Framework Directive

(2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

Figure 1 and Figure 2 illustrate the composition of hazardous wastes generated by industrial and commercial operators in 2014.


Figure 1: The share of wastes from mining and quarrying of the total quantity of hazardous wastes generated

by industrial and commercial oparators in 2014.

Figure 2: The composition of hazardous wastes generated by industrial and commercial operators in 2014,

without wastes from mining and quarrying.

74%

Total quantity: 54,720 t

(without wastes from mining and quarrying)



4.2.2 Origin of hazardous wastes in Serbia

Hazardous waste generation in the Sector “Mining and quarrying”

According to Statistical Office (2015-1 and 2015-2) the amount of hazardous waste generated by the sector of “Mining and quarrying” (Classification of Economic Activities, CEA) varied during 2010 and 2014 between 11.0 Mio and 16.7 Mio tonnes between 2010 and 2014. These quantities represent mainly such hazardous mining wastes, which are covered by the Mining Waste Directive (2006/21/EC) and excluded from the Waste Framework Directive (2006/21/EC).

The SEPA-statistics on hazardous waste generation for the reference year 2014 include 155,044 tonnes of hazardous wastes resulting from exploration, mining, quarrying or from physical and chemical treatment of minerals was in 2014. However, as of the reference year 2015, these wastes are not anymore included in the SEPA-statistics on hazardous waste generation, since it is regard-ed that they are not covered by the Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

Hazardous waste generation from the manufacturing industry

According to Statistical Office (2015-1) the amount of hazardous waste generated by the sector of manufacturing industry (CEA) varied during 2010 and 2013 between 67,000 and 99,000 tonnes per year. In 2014 the total amount of hazardous waste generated by the manufacturing industry was only 22.000 tonnes. The strong decrease was caused by the fact that specific acids generated by one company were regarded as waste until 2013 but received a product status in 2014 (Statisti-cal Office 2015-2).

The most important hazardous waste categories are acid, alkaline or saline wastes (between 45,000 and 70,000 tonnes per year between 2010 and 2013) followed by hazardous combustion wastes (between 13,000 and 32,000 tonnes per year) and chemical wastes (between 3,000 and 6,000 tonnes per year). (Statistical Office 2015-2)

Within the manufacturing industry, the highest levels of hazardous waste generation were recorded for the CEA “Manufacture of chemicals and chemical product, basic pharmaceutical products and pharmaceutical preparations, rubber and plastic products (between 46.000 and 73.000 tonnes per year), followed by the “Manufacture of basic metals and fabricated metal products (between 16.000 and 35.000 tonnes per year). (Statistical Office 2015-1)

During the period 2010-2012, the overall quantities of waste (hazardous and non-hazardous) gen-erated in the section of manufacturing constantly decreased. The main reason for this is seen in the decrease of waste generation in the of manufacture of basic metals and fabricated metal prod-ucts, excluding machines, as well as in the manufacture of chemicals and chemical products, basic pharmaceutical products, pharmaceutical preparations and rubber and plastic. From 2013 onwards the waste amounts increased again. (Statistical Office 2015-1)

The following table shows the development of waste generation in the section of manufacturing from 2010 to 2014 as presented in the waste statistics of the Statistical Office.


Table 5: Generated quantities of waste in manufacturing industry. ()

Generation (t)

2010 2011 2012 2013 2014

Non-hazardous 1,036,276 1,033,640 693,059 725,765 832,164

Hazardous 99,081 92,970 66,772 95,522 22,159

Total 1,126,357 1,126,610 759,831 821,287 854,323

Sources: Statistical Office (2015-1), Statistical Office (2015-2)

Hazardous waste generation from the sector “Electricity, gas, steam and air conditioning supply”

According to Statistical Office (2015-2) the amount of hazardous waste generated by the sector of electricity, gas, steam and air conditioning supply (CEA) during the past 5 years varied be-tween below 1,000 and approximately 1,500 tonnes per year. The share of hazardous waste gen-erated in this section was low in relation to the quantities of non-hazardous waste. The most im-portant hazardous waste types generated in the sector of electricity, gas, steam and air condition-ing supply in the years 2010-2013 were chemical wastes and wood wastes. (Statistical Office (2015-2).

During the period 2010-2013, the overall quantities of waste (hazardous and non-hazardous) gen-erated in the section of Electricity, gas, steam and air conditioning supply varied only slightly. Non-hazardous combustion waste with a share of over 99% of the total quantities is the most prevalent category of waste in this section.

The following table shows the development of waste generation in the section of electricity, gas, steam and air conditioning supply from 2010 to 2014 as presented in the waste statistics of the Sta-tistical Office.

Table 6: Generated quantities of waste in the sector of electricity, gas, steam and air conditioning supply from

2010 to 2014.

Generation (t)

2010 2011 2012 2013 2014

Non-hazardous 6,018,807 6,354,244 5,742,971 6,198,002 4,476,713

Hazardous 1,480 1,423 1,379 1,078 971

Total 6,020,287 6,355,668 5,744,350 6,199,079 4,477,684

Sources: Statistical Office (2015-1), Statistical Office (2015-2)

Hazardous waste generation from the construction sector

According to SEPA (2015-2) the amount of hazardous C&D waste generated in 2014 was 2,259 t. In total 201.775 t of C&D waste were generated. With a generation of 1.812 tonnes the most im-portant hazardous waste type is “soil and stones containing dangerous substances, 17 05 03*.

The survey of the Statistical Office shows a slightly different picture. According to Statistical Office (2015-1) the amount of hazardous waste generated in the construction sector in 2013 was 373 t. The total generation of waste in the construction sector was 328.235 t, of which 245.000 tonnes were uncontaminated soils. The most important hazardous waste types generated by the construc-tion sector in 2013 were “used oils” (132 tonnes) and discarded vehicles (173 tonnes). (Statistical Office 2015-1).


Hazardous waste generation from the waste treatment sector

According to MAEP (2015) the amount of waste generated by the waste treatment sector in 2014 was 282,351 t, of which 1,277 tonnes were classified as hazardous waste.

The most important hazardous waste types generated by the waste management sector were 19 02 05* “sludges from physico/chemical treatment containing hazardous substances” (593 tonnes), 19 08 13* “sludges containing hazardous substances from other treatment of industrial waste wa-ter“ (372 tonnes) and 19 12 11* „other wastes (including mixtures of materials) from mechanical treatment of waste containing hazardous substances“ (210 tonnes). (SEPA 2015.)

Hazardous waste generation from the health sector

According to Statistical Institute (2015-1) the total amount of “Health care and biological wastes“ in 2013 was 2,702 tonnes, of which 2,231 tonnes were hazardous. In total 28,868 tonnes of waste were generated in the sector of human health and social protection (CEA) in 2013. (Statistical Insti-tute 2015-1.)

The data of SEPA indicates that 2,931 tonnes of “Wastes” from human or animal health care and/or related research was generated in Serbia in 2014, of which 2,682 tonnes were hazardous. Data are based on 267 health institutions that generate such waste in the course of their activities. (MAEP 2015.)

The following table presents per waste type the quantities of waste generated in the health care sector in 2014, based on the data of SEPA.

Table 7: Wastes generated in the health sector in Serbia in 2014 (MAEP 2015.)

Code Waste Quantity

generated (t)

18 01 03* Wastes whose collection and disposal is subject to special re-quirements in order to prevent infection

2,643

18 01 01 Sharps (except 18 01 03) 149

18 01 02 Body parts and organs including blood bags and blood preserves (except 18 01 03)

44

18 01 04 Wastes whose collection and disposal is not subject to special re-quirements in order to prevent infection (for example dressings, plaster casts, linen, disposable clothing, diapers)

36


26

18 01 06* Chemicals consisting of or containing dangerous substances 6

18 01 08* Cytotoxic and cytostatic medicines 6

18 01 09 Medicines other than those mentioned in 18 01 08 6

18 02 06 Chemicals other than those mentioned in 18 02 05 5

18 02 06 Medicines other than those mentioned in 18 02 07 4

Other waste types 4

TOTAL 2,931


For the National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceutical Waste, waste generation rates for planning purposes have been determined based on through data analysis, including interpretation and extrapolation of available data. Based on specific indicators and on the data on the number of healthcare facilities in Serbia and on the num-ber of beds and occupancy rates, the total annual generation rate of infectious waste (18 01 03*) in Serbia has been estimated to be in the order of 4,500 to 5,000 tonnes per year of which some 20 % originates from the treatment of out-patients, 75 % from the treatment of in-patients and 5 % from micro-biology tests. (COWI & EURO HEALTH GROUP 2013)

According to the National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceutical Waste, the annual generation rate of cytostatic and cytotoxic waste (18 01 08*) can be estimated to be in the order of 70 to 75 tonnes of which 15 tonnes vials contaminated with undiluted cytotoxic and cytostatic substances. The remaining 55 to 60 tonnes comprises sharps, plastic tubing and glass and plastic bottles contaminated with diluted cytotoxic and cyto-static substances (typically a solution of 1% medication in physiologic infusion liquid). (COWI &

EURO HEALTH GROUP 2013)

Other Pharmaceutical Waste (18 01 09 – non-hazardous) is generated in healthcare facilities, pharmacies as well as in households. The total pharmaceutical waste generation in all public HCIs and public pharmacies in Serbia has been estimated to be in the order of seven tonnes per year. Waste generation in the private sector is expected to be in the order of one to three tonnes per year. For pharmaceutical waste generation by households, basic data are lacking and only an edu-cated guess can be made based on sparse data from trials and data reported by other European countries. For planning purposes a waste generation rate of 50 tonnes per year is assumed bring-ing the total pharmaceutical waste generation rate to an estimated 60 tonnes per year. (COWI &



Hazardous waste generation from households

According to the Environmental Protection Report 2014, the total quantity of municipal waste gen-erated in Serbia in 2014 was 2.13 Mio tonnes. No Information on the share of hazardous wastes in municipal waste has been provided in the report. (MAEP 2015)

4.2.3 Quantities of hazardous wastes treated in Serbia

According to information available from SEPA, in 2014 in total about 6,000 tonnes of hazardous waste were disposed of at landfills (operations D1 and D5), 4,300 t were used for energy recovery (operation R1), 75,100 t were treated in operations aiming at recycling/ material recovery (opera-tions R2-R11) and 23,700 t were taken over to storage / exchange of waste in Serbia. The follow-ing table shows the quantities of hazardous wastes treated in Serbia by recovery / disposal opera-tion. It is worth noting, that these quantities do not cover the treatment of “Wastes containing haz-ardous substances from physical and chemical processing of non-metalliferous minerals” from min-ing and quarrying (generated quantity: 155,000 t).

Table 8: The quantities of hazardous wastes treated in Serbia by recovery / disposal operations in 2014.

Code Type of disposal / recovery operation Quantity treated (t)

D1 Deposit into or onto land 500

D5 Specially engineered landfill 5,495

R1 Use principally as a fuel or other means to generate energy 4,299

R2 Solvent reclamation/regeneration 348

R3 Recycling/reclamation of organic substances which are not used as solvents

658

R4 Recycling/reclamation of metals and metal compounds 26,579

R5 Recycling/reclamation of other inorganic materials 24,559

R7 Recovery of components used for pollution abatement 4,164

R9 Oil re-refining or other reuses of oil 2,646

R10 Land treatment resulting in benefit to agriculture or ecological improvement

15,907

R11 Use of wastes obtained from any of the operations numbered R1 to R10

280

R12 Exchange of wastes for submission to any of the operations numbered R1 to R11

5,790

R13 Storage of wastes pending any of the operations numbered R1 to R12

17,859

TOTAL 109,084

The following figure illustrates the shares of different treatment types (excluding R12&R13) for the hazardous wastes generated by industrial and commercial sources in 2014, without hazardous wastes from mining and quarrying. Operations aiming at recycling/ material recovery (operations R2-R11) accounted for the biggest share of the treated quantities.


Figure 3: The shares of different treatment types for the hazardous wastes generated by industrial and com-

mercial sources in 2014, without hazardous wastes from mining and quarrying.

4.2.4 Quantities and waste types of hazardous waste landfilled in Serbia

According to information available from SEPA, in 2014 in total about 6,000 tonnes of hazardous waste (without wastes from mining and quarrying) were landfilled on 4 of the 6 Serbian landfills for hazardous waste. The following table shows the quantities landfilled per waste type.

Table 9: Quantities of hazardous waste landfilled in Serbia per waste type, 2014 (Source: administrative data

of SEPA 2016)

Waste code Waste type Quantity landfilled

(t)

10 02 13* Sludges and filter cakes from gas treatment containing hazardous substances

4,097

12 01 09* Machining emulsions and solutions free of halogens 273

12 01 12* Spent waxes and fats 122

17 06 01* Insulation materials containing asbestos 5

17 06 03* Other insulation materials consisting of or containing hazardous substances

85

17 06 05* Construction materials containing asbestos 350

17 09 03* Other construction and demolition wastes (including mixed wastes) containing hazardous substances

60

19 02 05* Sludges from physico/chemical treatment containing hazardous substances

524

19 03 06* Wastes marked as hazardous, solidified 178

19 08 13* Sludges containing hazardous substances from other treatment of industrial waste water

300

TOTAL 5,995

Total quantity: 54,720 t (without wastes from mining and quarrying)


The following figure illustrates the shares of different waste types in the landfilled quantity in 2014. The waste type 10 02 13* “Sludges and filter cakes from gas treatment“ accounted for the biggest share in the landfilled quantities.

Figure 4: The shares of different waste types in the landfilled quantity in 2014.



4.2.5 Quantities and waste types of hazardous waste used for energy recovery in Serbia

According to information available from SEPA, in 2014 in total about 4,300 tonnes of hazardous waste were used for energy recovery in Serbia. The following table shows the quantities used for energy recovery per waste type.

Table 10: Quantities of hazardous waste used for energy recovery in Serbia in 2014 (Source: data provided by

SEPA dated with 12th of April 2016)

Waste code Waste type Quantity used for

energy recovery (t)

12 01 07* Mineral-based machining oils free of halogens (except emul-sions and solutions)

4

13 01 13* Other hydraulic oils 1

13 02 05* Mineral-based non-chlorinated engine, gear and lubricating oils 168

13 02 06* Synthetic engine, gear and lubricating oils 1

13 02 08* Other engine, gear and lubricating oils 16

13 03 10* Other insulating and heat transmission oils 17

13 05 06* Oil from oil/water separators 1,866

13 08 99* Wastes not otherwise specified 27

15 01 10* Packaging containing residues of or contaminated by hazard-ous substances

17

15 02 02* Absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by hazardous substances

100

16 01 07* Oil filters 2

16 07 08* Wastes containing oil 2,038


13

19 12 11* Other wastes (including mixtures of materials) from mechanical treatment of waste containing hazardous substances

29

TOTAL 4,296

The following figure illustrates the shares of different waste types in the quantity of hazardous waste used for energy recovery in 2014. The waste types 16 07 08* “Wastes containing oil” and 13 05 06* “oil from oil/water separators” accounted for the biggest shares in the quantity used for en-ergy recovery.


Figure 5: The shares of different waste types in the quantity of hazardous waste used for energy recovery in

2014.


4.2.6 Quantities and waste types of hazardous waste treated in operations aiming at recycling/material recovery in Serbia

According to information available from SEPA, in 2014 in total about 75,100 tonnes of hazardous waste were treated in operations aiming at recycling/material recovery (operations R2-R11) in Ser-bia. The following table shows the quantities treated in operations R2-R11 per waste type.

Table 11: Quantities of hazardous waste treated in operation aiming at recycling/material recovery in Serbia in

2014 (Source: data provided by SEPA dated with 27th of June 2016)

Waste code Waste type Quantity treated in operations R2-R11

(t)

06 01 04* Phosphoric and phosphorous acid 23,902

05 01 06* Oily sludges from maintenance operations of the plant or equipment

9,900

20 01 35* Discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components

9,442

16 02 13* Discarded equipment containing hazardous components other than those mentioned in 16 02 09 to 16 02 12

8,542

10 02 07* Solid wastes from gas treatment containing dangerous sub-stances

6,086

05 01 03* Tank bottom sludges 3,456

01 05 05* Oil-containing drilling muds and wastes 3,000

01 05 06* Drilling muds and other drilling wastes containing dangerous substances

1,750


1,540

16 06 01* Lead batteries 1,434

13 08 99* Wastes not otherwise specified 1,053

16 01 04* End-of-life vehicles 720

17 05 03* Soil and stones containing dangerous substances 650

Other waste types 3,667

TOTAL 75,143

It is worth noting, that the quantities of hazardous wastes reported as recycled/recovered may in-clude double countings because no clear distinction between pretreatment and final treatment can be made based on the reported R-codes. In addition, the allocation of R-codes sometimes seems to be questionable (e.g. use of hazardous waste for “Land treatment resulting in benefit to agricul-ture or ecological improvement”). The following table shows the quantities of hazardous waste treated in 2014 in operations aiming at recycling/material recovery per type of operation (R-codes).


Table 12: The quantities of hazardous waste treated in 2014 in operations aiming at recycling/material recov-

ery per type of operation (R-codes).

R-code Type of recovery operation Quantity treated in operations R2-R11

(t)

R2 Solvent reclamation/regeneration 348

R3 Recycling/reclamation of organic substances which are not used as solvents 658

R4 Recycling/reclamation of metals and metal compounds 26,579

R5 Recycling/reclamation of other inorganic materials 24,559

R7 Recovery of components used for pollution abatement 4,164

R9 Oil re-refining or other reuses of oil 2,646

R10 Land treatment resulting in benefit to agriculture or ecological improvement 15,907

R11 Use of wastes obtained from any of the operations numbered R1 to R10 280

TOTAL 75,143

The following figure shows the shares of different waste types in the quantity of hazardous waste treated in operations aiming at recycling/material recovery (R2-R11). The waste types 06 01 04* “Phosphoric and phosphorous acid” and 05 01 06* “Oily sludges from maintenance operations of the plant or equipment” accounted for the biggest shares in the quantity treated in operations aim-ing at recycling/material recovery in 2014.

Figure 6: The shares of different waste types in the quantity treated in operations aiming at recycling/material

recovery (R2-R11) in 2014..



4.2.7 Treatment of the hazardous waste from the construction sector

Construction waste is disposed at disposal sites for municipal waste and is often used as inert ma-terial to cover waste at landfill. According to the Environmental Protection Report (MAEP 2015) re-cycling of construction waste has not been established by now (asphalt is recycled in small quanti-ties). However, according to Serbian EPR 2015 about 80% of construction waste could be reused. A considerable amount of C&D waste is dumped illegally.

According to SEPA, in 2014 710 tonnes of hazardous construction and demolition waste (chapter 17) were reported to have been taken over to recovery operations. The hazardous waste types and treatment operations include:

170106* “mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing dangerous substances” treated by treatment code R10 “land treatment resulting in benefit to agriculture or ecological improvement”,

170410* “cables containing oil, coal tar and other dangerous substances” treated with treat-ment code R4 “Recycling/reclamation of metals and metal compounds”,

170503* “soil and stones containing dangerous substances” treated with treatment code R10 “land treatment resulting in benefit to agriculture or ecological improvement” and

170603* “other insulation materials consisting of or containing dangerous substances” treated with treatment code R13 “storage of waste pending to any other recovery operations”.

The following table shows by waste code the quantities of hazardous construction and demolition waste (chapter 17) taken over to recovery operations in 2014.

Table 13: Quantities of hazardous construction and demolition waste (category 17) taken over to recovery

operations in the year 2014. (Source: data provided by SEPA dated with 23rd of February 2016)

Waste Code Waste Type Quantity treated (t)

17 01 06* Mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing hazardous substances

2

17 04 10* Cables containing oil, coal tar and other hazardous sub-stances

36

17 05 03* Soil and stones containing hazardous substances 650

17 06 03* Other insulation materials consisting of or containing haz-ardous substances

22

TOTAL 710

In addition to the quantities presented above, in 2014 500 tonnes of hazardous construction and demolition wastes (chapter 17) were disposed of in landfills in Serbia. The following table shows the landfilled quantities of hazardous construction and demolition wastes by waste code in 2014.


Table 14: Quantities of C&D waste disposed of in 2014 by waste code (Source: data provided by SEPA dated

with 23rd of February 2016).


17 06 01* Insulation materials containing asbestos 5

17 06 03* Other insulation materials consisting of or containing haz-ardous substances

85

17 06 05* Construction materials containing asbestos 350

17 09 03* Other construction and demolition wastes (including mixed wastes) containing

60

TOTAL 500

4.2.8 Treatment of the hazardous waste from the health sector/medical waste

According to the data presented in the Environmental Protection Report 2014, altogether 2,148 tonnes of wastes from human or animal health care and/or related research (chapter 18) were treated in Serbia in 2014. Table 15 presents these treated quantities by waste types. (MAEP 2015) The treated quantities include also wastes taken over to storage of wastes (Operation code R13).

Table 15: Treated quantities of wastes from human or animal health care and/or related research (Chapter 18)

in 2014 in Serbia (MAEP 2015).


18 01 01 Sharps (except 18 01 03) 162

18 01 02 Body parts and organs including blood bags and blood pre-serves (except 18 01 03)

2

18 01 03* Wastes whose collection and disposal is subject to special requirements in order to prevent infection

1,971

Other waste types 13

TOTAL 2,148

The existing Health Care Waste Management (HCWM) system in Serbia is focused on the treat-ment of infectious waste and consists of a network of Central Treatment (CTPs) and Local Treat-ment Points (LTPs) where infectious healthcare waste is treated by means of steam sterilization in autoclaves. Subsequently the treated infectious waste may or may not be shredded depending on whether the CTP or LTP is equipped with a shredder or not. After treatment the now non-infectious waste is deposited on dumpsites or landfills. CTPs usually have been established in central hospi-tals in the main town of a District, while LTPs have been established in remote healthcare institu-tions (HCIs) and in the big healthcare centers, including the four clinical centers, generating large amounts of infectious waste.


4.2.9 Quantities of hazardous wastes imported/exported to/from Serbia

During 2014 in total 25,004 t of hazardous waste were exported from Serbia (MAEP 2015). The most important waste type exported was 16 06 01* “lead batteries” (15,427 t). The lead batteries were exported to Bulgaria, Romania and Slovenia.

Generally speaking, import of hazardous waste to Serbia is prohibited. However, certain types of hazardous waste, which are needed as secondary raw materials in the processing industry in Ser-bia, may exceptionally be imported. Such import require a permit. The Government decides on the types of the hazardous waste which may be imported as secondary raw materials. During 2014 there was only one import of hazardous waste (24 t of lead-acid batteries imported from Bosnia and Herzegovina).

Table 16: Exports of hazardous wastes from Serbia in 2014 (Source: data provided by SEPA dated with 12th

of April 2016)

Waste code Waste type Quantity exported

(t)

16 06 01* Lead batteries 15,427

17 05 03* Soil and stones containing hazardous substances 2,645

10 02 07* Solid wastes from gas treatment containing hazardous substances 1,978

10 04 01* Slags from primary and secondary production 1,308

16 02 15* Hazardous components removed from discarded equipment 1,084

08 01 13* Sludges from paint or varnish containing organic solvents or other hazardous substances

321

16 08 02* Spent catalysts containing hazardous transition metals or hazard-ous transition metal compounds

297

10 04 02* Dross and skimmings from primary and secondary production 290

07 05 13* Solid wastes containing hazardous substances 256

20 01 35* Discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous compo-nents

222

08 01 11* Waste paint and varnish containing organic solvents or other haz-ardous substances

213

15 02 02* Absorbents, filter materials (including oil filters not otherwise speci-fied), wiping cloths, protective clothing contaminated by hazardous substances

133

19 12 11* Other wastes (including mixtures of materials) from mechanical treatment of waste containing hazardous substances

128

16 02 09* Transformers and capacitors containing PCBs 118

16 03 05* Organic wastes containing hazardous substances 116

Other waste types 469

TOTAL 25,004

The exported quantities presented in Table 16 include approx. 2 t of waste encoded as 18 01 08 “cytotoxic and cytostatic medicines”.


The following figure illustrates the shares of different waste types in the exported total quantity of hazardous waste in 2014.

Figure 7: The shares of different waste types in the total quantity exported from Serbia in 2014.

4.2.10 Generation, treatment and shipment of special waste streams

Waste generation from products that become waste after their use (special waste streams)

The following table sums up the generated amounts of special waste streams in 2014, as present-ed in the Environmental Protection Report 2014 (MAEP, 2015). It needs to be noted, that the quan-tities presented here are based on the annual reports of twaste generators and do not include wastes generated by households14.

14 Every waste generator, except for households, shall maintain and keep daily records on waste and shall submit regular

annual report to SEPA, including the types and quanties of wastes generated


Table 17: Generation of special waste streams, 2014 (Sources: MAEP, 2015 and SEPA, 2015-2)

Special waste stream Waste generation 2014 (t)

End-of-life vehicles 3,006*

Batteries and accumulators 752

Waste electrical and electronic waste 1,108

Asbestos waste 1,542

Waste Oil 13,777

*Including 1,196 tonnes of hazardous ELV and 1,810 t of non-hazardous ELV (without liquids and other hazardous components).

Treatment of wastes from products that become waste after their use (special waste streams) The following table sums up the amounts of special waste streams disposed of and treated in Ser-bia in 2014, as presented in the Environmental Protection Report 2014. (MAEP, 2015).

Special waste stream Quantity treated (t) Quantity landfilled (t)

End-of-life vehicles 1,914

Batteries and accumulators 10,910

Waste electrical and electronic waste

20,972 0.1

Asbestos waste 1,647

Waste Oil 10,136

Import and export of wastes from products that become waste after their use (special waste streams)

The following table sums up the amounts of special waste streams imported to and exported out of Serbia in 2014, as presented in the Environmental Protection report 2014. (MAEP, 2015).

Special waste stream Quantity exported (t) Quantity imported (t)

End-of-life vehicles (non-hazardous) 184 -

Batteries and accumulators 15,427 24

Waste electrical and electronic waste

240 -

Asbestos waste - -

Waste Oil - -

4.2.11 Generation and treatment of PCB waste and other wastes containing POPs

Preliminary inventory of PCB, prepared in 2006-2007, showed the presence of 767 transformers in use (total mass of 3300 t), 4394 condensers in use (total mass 172 t) and 41 rotor resistors (total mass of 3253 kg) but the realistic figures are expected to be much higher since significant discrep-ancies have been observed between data provided by local equipment manufacturers and data ob-tained during inventory compiling. Current updates on the preliminary inventory indicate that an es-timated total quantity of PCB oils is 1822.5 tons corresponding to 7290 tons of equipment.


It is foreseen that in Serbia equipment containing more than 5 dm3 of PCB will be disposed of or decontaminated until 2019/20 at the latest. Equipment containing between 0.005% and 0.05% by weight (equivalent to 500 ppm or 500 mg/kg) of PCBs shall be decontaminated or disposed of when it is out of use. At present, there are no locations intended for permanent storage and decontamination of PCB-contaminated equipment and waste in Serbia. Safe storing of PCB does not exist in Serbia till now. There is no facility for PCB waste treatment in Serbia and this waste is exported for treatment Waste containing dioxins in an amount of > 10,000 ng ITEQ/kg (national limit) have to be managed in accordance with the POPs Regulation. The assessment of current POPs-management in Serbia is based on preliminary inventories of pesticides, PCB and POPs (PCDD/PCDF, HCB). There are about 6 t of POPs waste pesticides in Serbia (DDT, Lindane) at 14 identified storages of waste pesticides. Due to lack of treatment facilities for hazardous wastes, also other POPs waste are presently stored in intermediate storage facilities prior to export to adequate disposal facilities (hazardous waste incinerators) abroad. POP-contaminated soils have to be identified and remediation has to take place in an environmen-tally sound manner. Locations where chlorinated organic pesticides were produced in the past, ar-eas characterized by the use of PCBs-containing equipment and industrial processes generating PCDD/PCDF and PAH releases, chlor-alkali facilities, facilities having used vinyl chloride mono-mers and chlorinated phenols (wood protection, leather tanning) stand the risk of contamination with POPs and require comprehensive investigations; the same applies to locations where pesti-cides POPs were handled or stored or disposed in the past (local dump sites). Contaminated soil, exhibiting more than 10,000ng PCDD/PCDF-ITEQ/kg (e.g. resulting from bombardment and burn-ing of PCBs transformers) or soil contaminated with PCBs is exported as HW for the purpose ap-propriate treatment. There are still a lot of “hot spots” of contaminated areas in Serbia. 4.2.12 Historical quantities of hazardous waste

Due to the lack of proper treatment possibilities, hazardous wastes have been stored in some in-dustrial installations in Serbia even over decades. These historical storages with potentially large waste quantities present potential danger for the environment and human health and are also a special challenge for the waste management planning. The historical storage facilities are often in-adequate and do not comply with the-state-of-the-art. Hazardous wastes (for example end-of-life vehicles) might also have been disposed of in unofficial dumpsites. For the time being, no systema-tized data on the “historical quantities” of hazardous waste stored in temporary storages or dis-posed of in unofficial dumpsites is available for the purposes of waste management planning.


4.2.13 Summarizing illustration of the generation and treatment of hazardous wastes in Serbia

The following table presents a summarizing illustration of the generation and treatment of hazard-ous wastes in Serbia in 2014 broken down according to the substance-oriented waste categories defined on the basis of the statistical European Waste Classification (EWCStat). The table is based on the data reported to the Serbian Environmental Protection Agency (SEPA).

The following issues should be taken into account, when the following illustration is interpreted: The data on waste generation includes 155,044 t of wastes from mining and quarrying (category

“Other mineral wastes”), which as of the reference year 2015 are not anymore included in the SEPA-statistics on hazardous waste generation, since it is regarded that these wastes are not covered by the Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

There is no exact information available on the generation of hazardous wastes from households and similar establishments. Theoretically, these waste quantities should however be included in the reported treated quantities of hazardous wastes.

The quantities of hazardous wastes reported as recovered may include double countings be-cause no clear distinction between pretreatment and final treatment can be made based on the reported R-codes.

Temporary storage can sometimes be the reason, if the total generated quantity of a waste cat-egory is higher/lower than the total treated quantity of the category.


Table 18: Generation and treatment of hazardous wastes in Serbia broken down according to the waste

categories defined in the European Waste Statistics Regulation (EC 2150/2002).

Waste category (EWC-Stat) Generation* (t)

Energy recovery (t)

Land-filling (t)

Export (t)

R2-R11

1 Spent solvents 98 5

3 Acid, alkaline or saline wastes 1,359 67 23,927

4 Used oils 12,415 2,072 395 20,858

6 Chemical Wastes 11,296 144 1,458

8 Industrial effluent sludges 2,762 2,038 300

10 Sludges and liquid wastes from waste treatment

595 524 74 29

12 Health care and biological wastes 2,682 13 1,544

17 Glass wastes 0

22 Wood wastes 397

24 Wastes containing PCB 72 128

26 Discarded equipment 4,824 2 1,306 18,065

28 Discarded vehicles 1,197 720

30 Batteries and accumulators wastes 753 15,427 1,434

36 Mixed and undifferentiated materials 3,348 117 36

38 Sorting residues 231 29 128 14

41 Mineral waste from construction and demolition

335 145 2

43 Other mineral wastes 155,155 354 1,750

45 Combustion wastes 10,513 4,099 3,649 6,112

47 Soils 1,812 2,645 652

51 Mineral waste from waste treatment and stabilised wastes

32 178

TOTAL 209,876 4,296 5,995 25,004 75,143

* of industrial and commercial waste


5 EXISTING WASTE COLLECTION SYSTEM AND NETWORK OF LARGE WASTE RECOVERY AND DISPOSAL FACILITIES INCLUDING ANY TREATMENT OF WASTE OILS, HAZARDOUS WASTE AND SPECIAL WASTE STREAMS

5.1 Present collection system for hazardous waste

5.1.1 Collection of hazardous waste from industry and commerce

There is no regular full-scale waste collection system for hazardous wastes introduced on the terri-tory of Serbia at present. Currently the collection system for hazardous wastes is primarily based on the economic value of the waste. E.g. oil wastes of a certain quality (high calorific value) or lead acid-batteries, which can be sold to users within the formal or informal waste management sector, are collected in any case.

No details are available about the collection of many hazardous wastes without a positive econom-ic value (acids, chemical waste, oil-contaminated waste, sludges, etc.).

In the Republic of Serbia, in total 250 permits for the collection of hazardous waste have been is-sued by 20.9.201615. Furthermore, 140 permits have been issued for the storage of hazardous waste.

5.1.2 Collection of hazardous waste from the construction sector

According to Article 35 of the Law on Waste Management hazardous waste has to be collected and transported separately. By that there is the obligation to avoid blending of hazardous and non haz-ardous wastes. In addition, in the draft by-law covering mineral C&D wastes obligations concerning the removal of hazardous substances before the demolition of buildings is proposed: Hazardous fractions (e.g. asbestos wastes) should be removed at the site of generation and kept separately until safe disposal in accordance with applicable regulation wherever feasible. If the hazardous components/materials cannot be removed before dismantling/de-construction the contamination of other material shall be kept to the minimum extent feasible.

According to data evaluation undertaken under previous projects and according to information

available up to now, no regular source separation and subsequent collection of hazardous waste

from C&D waste (e.g. asbestos containing waste and WEEE) exists. Only in few cases it is report-

ed that hazardous substances are source separated and directed to adequate treatment.

For asbestos containing waste, which constitutes a relevant hazardous waste stream from the con-

struction sector, no regular source separation and subsequent collection system has been estab-

lished in Serbia. For 2014 an amount of 111 t asbestos waste was notified to SEPA, while it can be

estimated from the assumed data on material in use and experiences from other countries that at

up to 45.000 t of asbestos containing wastes are produced per year.

15 http://www.sepa.gov.rs/index.php?menu=20174&id=20055&akcija=ShowExternal


5.1.3 Collection of hazardous waste from the medical sector

Inappropriate medical waste management is a significant problem due to lack of waste separation in health institutions. In 2007, Ministry of Health initiated specific activities related to introduction of uniformed system of medical waste management in Serbia, particularly with the category of infec-tious medical waste. Vehicles for medical waste transport have been procured, and training of medical staff for separation of waste in healthcare institutions has been conducted. Separation of infectious medical waste from other waste has started in public and private healthcare institutions and veterinary organizations.

The existing health care waste management system in Serbia is focused on the treatment of infec-tious waste and consists of a network of Central Treatment Points and Local Treatment Points. The Central Treatment Points have been established in general hospitals typically in the main town or city within a District, while Local Treatment Points have been established in the more remote healthcare institutions as well as in the largest healthcare institutions, including the four clinical centres, generating large amounts of infectious waste that warrant to have a self sufficient system in place. (COWI & Euro Health Group 2013)

The Central Treatment Points have been provided with vehicles in order to collect and treat infec-tious waste from a number of other health care institutions which do not have their own treatment equipment while Local Treatment Points typically treat, in addition to their own waste, waste from only a few other health care institutions which deliver their waste for treatment. (COWI & Euro Health Group 2013)

Some public pharmacies accept pharmaceutical waste from households but few institutions actively promote the service. Pharmaceutical waste from households often either accumulates in household or it is disposed of into the sewer or communal waste containers. Without treatment capacity in place in Serbia and without arrangements for the funding of collection, transport and export destruction abroad, the pharmaceutical institutions that do accept pharmaceutical waste from households store the waste in a variety of places and circumstances. In healthcare institutions, not being pharmacies, pharmaceutical waste has accumulated over a period of 40 years or more. (COWI & Euro Health Group 2013)

A system for the management of chemical waste from the healthcare sector is not yet in place. Chemical waste is managed by individual healthcare facilities whereby discharge into the sewer system is the most frequently used method. Some hazardous chemical waste is stored indefinitely, while export for incineration abroad and handing over to treatment in the country is taking place on an occasional basis. (COWI & Euro Health Group 2013)

5.1.4 Collection of hazardous waste from households

Collection rate of municipal waste collection amounts to 60% in the Republic of Serbia. Collection is organized primarily in urban areas, whereas rural areas are significantly less covered. Most of local self-government units have the basic waste collection equipment; however there is a lack of appropriate equipment for enlarged separation and collection duties. Centers for separate collection of waste exist in Belgrade, Čačak and sporadically in other local self-government units in the Republic of Serbia, where municipal waste is collected in separate containers intended for collection of different types of waste (metal, glass, paper, PET, cans and so on). There is a facility for waste separation of recyclable waste in Novi Sad.


Certain hazardous wastes from households like WEEE, batteries are collected under the control of municipalities and in the context of special waste streams. For other hazardous wastes from households, e.g. waste oil, pharmaceutical and chemical waste, varnishes,no regular collection system has been established in Serbia untill now. There is no specific legislation on separate col-lection and management of hazardous household wastes in Serbia yet.

5.1.5 Collection of hazardous waste streams covered by extended producer responsibility systems

According to MAEP (2012a) separate collection of WEEE by the official waste management sector is more or less restricted to collection from businesses and is predominantly conducted by the op-erators of WEEE treatment plants themselves. No regular collection system for WEEE from house-holds and small businesses exists. Municipalities do not provide collection facilities for separate collection of wastes from households.. Retailers have according to legislation on WEEE the obliga-tion to take back WEEE on a one-for-one basis, however, indication is given that the option is hard-ly used by end-users. At irregular time intervals non-systematic collection campaigns are organized by waste collection companies (providing large containers for bulky waste and metal scrap) and producers of EEE. WEEE containing valuable materials is furthermore collected by numerous ac-tors of the informal waste collection sector, who provide pick-up services from households. Hand-over of WEEE might take place at collection sites for various waste streams from households in Belgrade,

According to MAEP (2012b) in Serbia there is no regular collection system for portable batteries and accumulators in place (. Municipalities do not provide collection facilities for batteries and ac-cumulators. Retailers do not take back batteries and accumulators. However, pilot projects related to the collection of portable batteries16 have been performed (e.g. collection at retailers in co-operation with Maxi Groceries andcollection at public buildings in the City of Uzice). The operators of WEEE-pretreatment faculities currently separate batteries and accumulators derived from dis-mantling of WEEE. Additionally they run collection activities.

The collection of automotive batteries, i.e. mainly lead-acid accumulators, is organized by the treatment plant operators in co-operation with “NGOs”. Serbia has not yet established a collection system for industrial batteries and accumulators. Information about collection facilities is not available.

The take-back system for end-of life vehicles is explicitly required to be cost free for the consum-ers. In 2016, more than 60 operators had permits for the collection of hazardous End-of-life vehi-cles. Collection facilities only take back the vehicles and forward them to dismantling facilities. which have to issue immediately a certificate of destruction, when they receive an ELV. It can be assumed, that ELV are often collected by informal collection activities, with the aim to sell spare parts and scrap metal for recycling. End-of-life vehicles might also be shipped abroad informally, or by privat persons.

As regards hazardous packaging waste a deposit system has been established in Serbia. Based on that provision, the Ministry adopted a list of different types of packaging containing chemicals for which the deposit system shall apply. Moreover, “the manufacturer and importer of chemicals shall, at their own expense, collect reusable packaging and the packaging waste originating from such chemicals, from the seller”. Regulations state that “the seller shall accept from the user the reusa-ble packaging and packaging waste originating from the substances in order to hand them over to the manufacturer or importer” and that “the user of chemicals shall return to the seller the used packaging and packaging waste”. The Serbian industry is faced with the lack of treatment facilities

16 personal information from Alksandar Jovanovic (EcoLogic) agreed with and on behalf of Let’s clean up Serbia, Oct. 2011


within the country and thus the hazardous packaging has to be exported for treatment, which will be at a higher cost. Thus, producers are using intermediate storage facilities followed by export. This is also the case for primary packaging waste from the crop protection products, which are not managed either individually or within any collective scheme.

5.1.6 Collection of PCB waste and other wastes containing POPs

Due to lack of treatment facilities for hazardous wastes, presently POPs waste (e.g. PCBs wastes, pesticides, packaging contaminated with POPs) are stored in intermediate storage facilities prior to export to adequate disposal facilities (hazardous waste incinerators) abroad. This intermediate storage of waste for final disposal is limited to a maximum of 12 months according to the Serbian landfills legislation. Some of these intermediate storage facilities are inadequate (“factory-storage”) and do not comply with the-state-of-the-art. This especially refers to POPs waste, whose owner is not always known. There are several authorized private companies which perform transport and export of POP waste for treatment in compliance with Waste Management Act.

5.2 Existing treatment facilities for hazardous wastes

In the Republic of Serbia in total 117 permits for treatment of hazardous waste and 3 permits for the disposal of hazardous waste were issued by 20.09.201617. Furthermore 140 companies had a permit for storage of hazardous waste by then.

The following table shows the distribution of permits issued by the Serbian Ministry of Agriculture and Environmental Protection and the Province of Vojvodina and others.

Table 19: Permits for treatment, disposal and storage of hazardous waste issued in the Republic of Serbia as of 20.09.2016

Type of permit

Number of issued permits

Serbian Ministry of Agriculture and Envi-ronmental Protection

Province of Vojvodina City of Belgrade

Treatment 84 43 0

Disposal 1 2 0

Storage 92 33 0

No complete picture on the actual type of treatment conducted and on treatment capacities in-stalled per treatment type is available. Furthermore, indication is given, that a considerable part of the companies having a permit for treatment, disposal or storage of hazardous waste are not active at the moment. Both, experts of SEPA and stakeholders have given such information.

17 http://www.sepa.gov.rs/index.php?menu=20174&id=20055&akcija=ShowExternal


5.2.1 Incineration

At present, there are no waste incineration plants in Serbia. However, two cement plants are avail-able for co-incineration of a wide range of different types of waste with and appropriate permissions for thermal treatment of waste

Currently, three cement plants are operating in the Republic of Serbia: 1) LAFARGE Serbia Ltd. (memeber of LafargeHolcim group), Beocin; 2) CRH Serbia Ltd. Popovac - Paracin and 3) TITAN Cementara Kosjerić Ltd., Kosjeric.

Currently two cement factories in Serbia have permits for the thermal treatment of hazardous and non-hazardous waste, while the third factory is in the procedure of obtaining the permit.

The processes where waste is used as raw material and/or as a source of energy, and where waste substitutes natural mineral resources (material recycling) and fossil fuels (energy recovery) used in the cement manufacturing, are called co-processing.

In the Serbian cement factories, co-processing took for the first time place in 2006. Between 2006 and 2014 nearly 210,000 tonnes of non-hazardous and hazardous waste were used as an alterna-tive fuel in the Serbian cement factories.

In addition, for the purpose of cement production, this industry in Serbia uses annually more than 300,000 tons of non-hazardous and hazardous waste (primarily fly ash and granulated blast fur-nace slag) as alternative raw materials.

5.2.2 Landfills

In 2015 there were 4 landfills in the Republic of Serbia, on which specific hazardous wastes can be disposed of. One of them, belonging to a steel company, has a permit for disposing of their own hazardous wastes. The other three are regional sanitary landfills for non-hazardous waste, which have landfill cells for wastes containing asbestos, for other hazardous construction and demolition waste or for solidified hazardous waste.. The following table gives an overview on the locations of the landfills and on types of waste landfilled in 201418.

18 SEPA register of waste management licences, status 11.12.2015


Table 20 Landfills that have cells for hazardous waste in the Republic of Serbia by 11.12.2015 (Source: SEPA database, data provided by SEPA on landfilled amounts of hazardous waste in 2014)

Company Location Capacity Waste types landfilled in 2014 in accord-

ance with the waste permits

HESTEEL Serbia Iron

Smederevo‐grad

. the designed capac-

ity of the cell for

hazardous waste

(tin sludge): 240,000

m³

sludges and filter cakes from gas treatment containing hazardous substances

sludges from physico/chemical treatment containing hazardous substances

sludges containing hazardous substances from other treatment of industrial waste water

machining emulsions and solutions free of halogens

spent waxes and fats

FCC EKO D.O.O. Regionalna de‐ponija Vrbak Lapovo

Lapovo

The remaining free

capacity to a height

of 6m : 876 m3.

Potential maximum

capacity to a height

of 30 m is 12,876

m3

construction materials containing asbestos

other insulation materials consisting of or containing

hazardous substances

other construction and demolition wastes (including

mixed wastes) containing hazardous substances

insulation materials containing asbestos

FCC Kikinda doo

Kikinda

Currently available

capacity (height

8m): 6,785 m3

Potential maximum

capacity (height

35m): 38,285 m3


other insulation materials consisting of or containing

hazardous substances

PWW DEPONIJA DVA DOO LESKOVAC

Leskovac‐grad

The designed capacity

for asbestos waste:

1,600 m3.

The amount of waste

containing asbestos

313 tonnes

(31.12.2015)

wastes marked as hazardous, solidified



5.2.3 CP-plants

At least 8 facilities, which had a permit for the treatment of hazardous waste at the end of 2016, can be classified as chemical-physical treatment plants. The following table gives an overview on these plants, on their locations and capacities and on types of waste they treat.

Table 21: Facilities for chemical-physical treatment of hazardous waste in the Republic of Serbia by 11.12.2015 (Source: SEPA database)

Company Location Capacity

(t/a) Waste types treated in 2014

Altis Chemicals Beograd‐Stari

Grad 50 re-refining of waste antifreeze, filtration,adsorption,

coagulation and regeneration of waste antifreeze

Cleaning System S Šabac

Delta eko system Kladovo 3,000 filtration, decanting distillation of waste oils

Eko Metal Irig chemical treatment of waste photo-chemicals

Ekokarika Beograd-

Savski Venac 3,000 treatment of non-chlorinated oils and emulsions by

ultrasound technology

Ekosekund Beograd -

Krnjača

Re-refining and Physical treatment (filtration, gravi-

ty separation, centrifugation and mixing of waste

oils, emulsions and oily waters.

Yunirisk

Beograd - Ra-

kovica

Purification andsolidification, in facility for ultra-filtration of waste

oils and oil emulsions.

Optima Forma Trstenik 400 filtration decanting of waste oils

5.2.4 Further treatment plants for hazardous waste

For the treatment of hazardous medical wastes, at least 47 permitted facilities existed in Serbia by the end of the year 2015. At least two plants for the cleaning und solidification of contaminated soils, had permits by the end of the year 2015. At least one facility had a permit for the treatment of asbestos waste and two facilities for the packing of asbestos waste.

One company, Oil Refinery Belgrade, has a permit for re-refining of waste oils with the capacity of 21.650 t/year. However, the facility has not been operating in the last years. One company, Mon-Bat, has a permit for recycling of lead batteries. This facility has not been operating in the last years either.

Several companies have permits vor pre-treatment, especially for manual dismantling, of hazard-ous WEEE. In April of 2012 twelve Serbian companies had a permit for the treatment of non-hazardous WEEE; 8 further companies had a permit for treatment of non-hazardous and hazard-ous WEEE. For four facilities more detailed information was available. The treatment capacity of these plants amounted to nearly 65,900 tons per year. However, no up-to-date picture of the facili-ties and their total capacities is available. One facility operates a universal cross flow shredder with subsequent separation and sorting for small appliances.


5.2.1 Summarizing illustration of the current status of the treatment of hazardous wastes in Serbia

The following Figure sums up the treatment of the hazardous wastes reported as generated in Ser-bia, without the hazardous wastes generated by mining and quarrying and without exported quanti-ties (total quantity: 210.000 t – 155.000 t – 10.000 t = 45.000 t) and compares these treated quanti-ties with the available capacities.

Figure 8: Present state of hazardous waste treatment activities and related capacities in Serbia.

There is no treatment capacity for the treatment of the wide range of hazardous industrial wastes on the territory of the Republic of Serbia: There are no authorized facilities for thermal and physi-cal-chemical treatment (CPA) of hazardous waste and only limited capacities for landfilling of haz-ardous waste. In recent years hazardous waste solidification and bioremediation processes have been applied as pre-treatment technique in single cases. Some registered facilities for physical treatment of specific waste streams are in operation. There is no location for central storage of hazardous waste, neither. In such circumstances, haz-ardous waste generators store hazardous waste temporarily in their own locations in temporary storages; due to the lack of alternatives, waste has been stored for 20 or more years in some of them. In the majority of cases, temporary storages of hazardous waste do not meet prescribed conditions.Therefore, needs for exports of hazardous waste for treatment are growing. Spatial plans in the Republic of Serbia have not defined locations for construction of facilities for hazardous waste management, and for now, there is no approved location for a further landfill of hazardous waste in Serbia.


6 EXPECTED TYPES, QUANTITIES, AND ORIGIN OF HAZARDOUS WASTE THAT WILL BE PRODUCED IN THE REPUBLIC OF SERBIA, IMPORTED OR EXPORTED INTO ANOTHER COUNTRY, INCLUDING ESTIMATIONS RELATED TO GENERATION OF SPECIFIC WASTE STREAMS

6.1 Introduction

Forecasts of hazardous waste generation are required for reliable waste management planning, in-cluding the planning of waste treatment facilities. The current status of waste quantities and waste composition serves as basis for waste prognosis.

The future waste quantities depend on several demographic, economic and social factors. The de-velopments in the waste management sector, e.g. the improvements in the separate collection of waste types, also have a high influence on the future waste quantities and waste composition. Forecasting future quantities of hazardous waste thus requires predicting a number of uncertain factors. The accuracy of the prognoses depends, of course, also strongly on the accuracy of the data on the current waste quantities and qualities.

The forecast presented here is based inter alia on the data on current waste quantities, on assump-tions on the developments of separate waste collection, on prognosis of the development of the economy and population and, in some cases, also on the data of selected other countries on the generation of specific hazardous waste streams. The Objectives of the estimation ar 1) to get a full picture of the hazardous wastes generated in Serbia and 2) to make prognosis of future quantities. Although details remain uncertain, the order of the magnitude of the results is assumed to be plau-sible.

6.2 Forecasts for selected waste categories

Chemical wastes and industrial effluent sludges

For the time being, the quantities of hazardous chemical wastes and industrial effluent sludges col-lected separately and reported by the generators of industrial and commercial wastes in Serbia seem to be low. There is no exact data available on the hazardous chemical wastes generated by households and similar establishments. It is expected that the separately collected and reported quantities of hazardous chemical wastes and industrial effluent sludges will rise in the coming years.

In order to get a complete estimation on the quantities of chemical wastes and industrial effluent sludges generated, and potentially separately collected in the near future in Serbia, extrapolations were made based on the waste statistics reported according to the European 2 Statistics Regula-tion by 5 countries (Croatia, Hungary, Poland, Slovenia and Romania). (Data Source: Eurostat 2016-1)

For the manufacturing industry and for the mining sector the extrapolations were based on the numbers of employees (Data Source: Eurostat 2016-2 and Statistical Office 2016-1). For the other sectors, the extrapolations were based on the numbers of inhabitants (Data Source: Eurostat 2016-3). The other sectors covered were agriculture, services, construction sector as well as waste-, wa-ter- and energy sectors.


Extrapolations were made for the following waste categories (EWC-Stat) of the EU Waste Statistics Regulation (EC 2150/2002): 1) Spent solvents, 2) Acid, alkaline or saline wastes, 3) Chemical wastes and 4) Industrial effluent sludges.

A Prognosis regarding the development of the population in Serbia19 was taken into account in the extrapolation. During the last years, the number of employees in the manufacturing sector in Serbia has been slightly decreasing whereas the number of employees in the mining sector has been slightly increasing20. For the prognosis of the future quantities of chemical wastes and industrial ef-fluent sludges it is however assumed, that the manufacturing sector and the mining sector will re-main relatively stable in Serbia in the near future.

The extrapolated quantity of the four categories concerned amounts in total to 38,600 t. The results of the extrapolation are presented in the following table.

Table 22: Results of the extrapolations made for the waste categories 1) Spent solvents, 2) Acid, alkaline or

saline wastes, 3) Chemical wastes and 4) Industrial effluent sludges.

Waste category (EWC-Stat) Extrapolated based on the waste statistics of Croatia, Hungary, Poland, Slovenia and Romania

Hazardous wastes from manufacturing (t)

Hazardous wastes from Mining and quarrying (t)

Hazardous wastes from other sectors (t)

Extrapolated total

1 Spent solvents 1,266 1 432 1,699

3 Acid, alkaline or saline wastes

3,467 8 1,558 5,033

6 Chemical Wastes 14,798 142 9,094 24,034

8 Industrial effluent sludges 3,755 2,881 1,215 7,850

Used oils

For the time being, the quantities of used oils collected separately and reported by the generators of industrial and commercial wastes in Serbia seem to be low. In addition, there is no exact data available on the used oils generated by households and similar establishments. It is expected that the collected and reported quantities of used oils will rise in the coming years. As stated in the draft Serbian National Waste Management Plan for Waste Oils, with the implementation of increasing environmental standards in Serbia, e.g. by widely used oil/water separators at petrol stations, gar-ages etc. relevant additional amounts of oil containing wastes from these installations will be gen-erated.

19 Population in Serbia in 2021: 6.897.312, data source Statistical Office 2014 20 Annual indicators on business activities of enterprises, Number of persons employed 2010 -2014, data source Statistical

Office 2014. Available at: http://webrzs.stat.gov.rs/WebSite/Public/PageView.aspx?pKey=168


In order to get a complete estimation on the quantities of used oils generated, and potentially sepa-rately collected in the near future in Serbia, extrapolations were made based on the waste statistics reported according to the European Waste Statistics Regulation by 5 countries (Croatia, Hungary, Poland, Slovenia and Romania). The same extrapolation methods were used as for chemical wastes and industrial effluent sludges. (Data Sources: Eurostat 2016-1, Eurostat 2016-2, Eurostat 2016-3 and Statistical Office 2016-1)

A Prognosis regarding the development of the population in Serbia21 was taken into account in the extrapolation. During the last years, the number of employees in the manufacturing sector in Serbia has been slightly decreasing whereas the number of employees in the mining sector has been slightly increasing22. For the prognosis of the future quantities of used oils it is however assumed, that the manufacturing sector and the mining sector will remain relatively stable in Serbia in the near future.

The extrapolated quantity of used oils amounts to 22,300 t. The results of the extrapolation are presented in Table 23.

Table 23: Results of the extrapolation made for used oils.

Waste category Extrapolated based on the waste statistics of Croatia, Hungary, Poland, Slovenia and Romania

Hazardous wastes from manufacturing (t)

Hazardous wastes from Mining and quarrying (t)

Hazardous wastes from other sectors (t)

Extrapolated total

4 Used oils 9,307 4,248 8,761 22,316

The estimation of future quantities of waste oils made for the Serbian National Waste Management Plan for Waste Oils is in line with the result of the extrapolation made for the waste category “Used oils”. According to the draft Serbian National Waste Management Plan for Waste Oils, approxi-mately 25,000 tonnes of waste oil are expected to be provided to the official waste treatment sec-tor by 2020. This estimation is based on the assumption that a waste oil collection rate of 50% of the oil and lubricants market input is achievable after 5 to 8 years of having launched a collection system and activities aiming in preventing illegal use/disposal of waste oil.

According to data reported to SEPA, about 19,400 t of mineral and synthetic oils and lubricants were placed on the market of the Republic of Serbia in 2014. The data on mineral and synthetic oils and lubricants put on the market does not seem to be complete. For this reason, estimations of the future quantities of waste oils cannot be made on the basis of this data.

21 Population in Serbia in 2021: 6.897.312, data source Statistical Office 2014 22 Annual indicators on business activities of enterprises, Number of persons employed 2010 -2014, data source Statistical

Office 2014. Available at: http://webrzs.stat.gov.rs/WebSite/Public/PageView.aspx?pKey=168


Healthcare waste (medical waste)

In the National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceutical Waste (Ministry of Health 2013), the total annual generation rate of infectious waste (18 01 03*) in Serbia has been estimated to be in the order of 4,500 to 5,000 tonnes per year of. For planning purposes a generation rate of 5,000 tonnes per annum is used, which is as-sumed to remain constant for the planning period 2013 to 2025.

According to the National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceutical Waste, the annual generation rate of cytostatic and cytotoxic waste (18 01 08*) can be estimated to be in the order of 70 to 75 tonnes of which 15 tonnes vials contaminated with undiluted cytotoxic and cytostatic substances. The remaining 55 to 60 tonnes comprises sharps, plastic tubing and glass and plastic bottles contaminated with diluted cytotoxic and cyto-static substances (typically a solution of 1% medication in physiologic infusion liquid). (COWI &


Other Pharmaceutical Waste (18 01 09 – non-hazardous) is generated in healthcare facilities, pharmacies as well as in households. The total pharmaceutical waste generation in all public HCIs and public pharmacies in Serbia has been estimated to be in the order of seven tonnes per year. Waste generation in the private sector is expected to be in the order of one to three tonnes per year. For pharmaceutical waste generation by households, basic data are lacking and only an edu-cated guess can be made based on sparse data from trials and data reported by other European countries. For planning purposes a waste generation rate of 50 tonnes per year is assumed bring-ing the total pharmaceutical waste generation rate to an estimated 60 tonnes per year. (COWI &


The generation of pharmaceutical waste is assumed to remain constant for the planning period 2013 to 2025. According to the European Waste Statistics Regulation, pharmaceutical wastes (18 01 08* and 18 01 09) are allocated to the EWC-Stat-category “Chemical Wastes”. Thus, pharma-ceutical wastes are included in the extrapolated quantity of the waste category “Chemical Wastes” (See Table 22).


WEEE

For the prognosis of the future quantities of generated WEEE, it is assumed that Serbia will strive for reaching the targets set for WEEE in the European legislation and that the future WEEE-collection achieved in Serbia will be comparable to that in other European countries.

The Directive 2002/96/EC on WEEE set a collection target of a minimum of 4 kg/inhabitant of WEEE from households to be achieved by all countries in 2009 at the latest. In Serbia, the Rule-book on WEEE, Article 15, defines this goal by 31 December 2019. In 2012, most of the EU Mem-ber States had met the collection target of 4 kg/inhabitant. Households are the main source of WEEE in the EU and WEEE from other sources represent more than 10% of the total WEEE col-lected only in a couple of countries. (Eurostat 2016-4)

The recast Directive (2012/19/EU), which entered into force in August 2012, introduces stepwise higher collection targets that will apply from 2016 and 2019. From 2016, the annual collection tar-get will be defined as the ratio between the collected amount and the average weight of EEE put on the market in the three preceding years. The collection target is set at 45 % in 2016 and will rise to 65 % in 2019. It is worth noting, that from 2018, the current limited scope of the Directive will be ex-tended to all categories of EEE, which might have an increasing effect on the quantities of WEEE recorded.

The quality of the data reported to SEPA on the quantities of EEE remains limited. According to SEPA, only about 7,000 t of EEE were put on the market in 2014 in Serbia (SEPA 2015 b). In 2010 in total at least 67,600 tons of EEE, corresponding to 9.3 kg per inhabitant, were placed on the Serbian market with 59,000 tons thereof being imported. In 2012 about 85,600 tons of new electri-cal and electronic deviceswere annually imported and placed on the market in Serbia.

Assuming a potential mass of EEE of 9-12 kg/cap/y in Serbia, it could be estimated that the collec-tion thresholds for Serbia would be: 45% would be equal to 5 kg/cap/y and

65% would be equal to 7 kg/cap/y.

These figures amount to WEEE quantities to be collected: approximately 37.000 tons per year until 2018 and

approximately 52.000 tons per year as of 2019.

Assuming that Serbia will meet the collection target of 4 kg/inhabitant of WEEE from households in 2020 at latest and taking into account the population prognosis of the Statistical office23, an overall collection amount of about 27,600 t in 2020 can be estimated for Serbia. If the collection rate reached only 3kg/inhabitant of WEEE from households, the overall quantity collected would amount to 20,700 t.

It is worth noting, that not all WEEE are hazardous. The data on discarded equipment reported by selected EU Member States according to the Waste Statistics Regulation (EC 2150/2002) suggest that about the half of the WEEE generated can be regarded as hazardous (Data source: Eurostat 2016-1). Thus, it can be estimated, that the quantity of hazardous WEEE generated in Serbia in 2020 will be between 10,400 t and 13,800 t.

23 Population in Serbia in 2021: 6.897.312, data source Statistical Office 2014.


Vehicles

According to SEPA (2015-3), In 282,050 tonnes of vehicles were put on the market in Serbia in 2014. This quantity includes the vehicles produced in Serbia and the vehicles imported to Serbia in 2014. It also includes those vehicles produced in Serbia, which were exported from Serbia abroad. The quantity put on the market according to SEPA is quite well in line with the quantities produced and imported. The number of passenger cars remaining in Serbian market, which can be calculat-ed based on the quantities produced /put on the market and on the quantities exported and import-ed, fits well together with the number of first-time registered cars in Serbia in 2014.

Estimations on the actual generation of ELV in Serbia were made for the draft Serbian Waste Man-agement Plan for End-of-life vehicles. Based on the annual numbers of first time registered pas-senger cars und on the growth of the fleet of passenger cars and on extrapolations from data of other countries the average quantity of ELV generated annually in Serbia was estimated to be be-tween 40,600 and 42,000 tonnes.

Over the last years the number of registered passenger cars in Serbia has increased on average 2.2 % annually. Assuming, that the car fleet will continue to increase 2.2% annually, the quantity of ELV will amount to 45,700 t in 2020.

The assumption, that the car fleet will continue to grow despite of the fact, that the population of Serbia is according to prognosis going to decrease, is feasible since it can be expected that the number of passenger cars per person will increase in the future. The current rate of 0.26 cars per inhabitant is relatively low. The annual increase of 2.2% of registered passenger cars would mean that in 2020 there would be 0.30 passenger cars per inhabitant in Serbia.

Lead-acid accumulators

Batteries and Accumulators Directive (2006/66/EC) includes a prohibition of the disposal by landfill or incineration of waste industrial and automotive batteries which practically means setting a 100% collection and recycling target for industrial and automotive batteries. According to EUROBAT (2014), the EU automotive lead-based battery collection and recycling rate has reach 99% by the year 2012. Also in Serbia, the collection rate of lead-acid accumulators seems already to be very high.

The quality of the data reported to SEPA on the quantities of Lead-acid accumulators remains lim-ited. According to SEPA, only about 9,000 t of Lead-acid batteries were put on the market in 2014 in Serbia (SEPA 2015 b). The data reported to SEPA by waste treaters and exporters indicates that at least 15,400 t of lead-acid batteries were collected in Serbia in 2014.

The most important influencing factor for the generation of lead-acid accumulators will be the de-velopment of the dimension of the Serbian car fleet. Over the last years the number of registered passenger cars in Serbia has increased on average 2.2 % annually. Assuming, that the car fleet, and thus the quantity of lead-acid accumulators, will continue to increase 2,2% annually, the quan-tity of discarded lead-acid accumulators will amount to 17,600 t in 2020.

Portable batteries and accumulators

For the prognosis of the future quantities of generated portable batteries and accumulators, it is as-sumed that Serbia will strive for reaching the targets set for batteries in the European legislation and that the future battery-collection achieved in Serbia will be comparable to that in other Europe-an countries.

The Batteries and Accumulators Directive (2006/66/EC) requires the following targets to be met: a 25% collection rate for waste portable batteries to be met by September 2012, rising to 45% by September 2016.


According to SEPA, only about 588 t of portable batteries were put on the market in 2014 in Serbia (SEPA 2015 b). Based on this data, the per capita quantity put on the market in Serbia would be very low, only 82 g per inhabitant.

On average, about 400 g of portable batteries per capita were put on the market annually in the Eu-ropean countries. In countries like Latvia, Hungary, Poland and Lithuania the annual per capita quantities of portable batteries put on the market are about 200 g. (EPBA 2013 and EPBA 2015)

Assuming that the per capita quantity of portable batteries put on the market in Serbia will in 2020 be 200 g, and assuming that the 25% collection rate will be met, the total quantity of portable bat-teries collected will be about 350 t. Assuming a higher quantity of 400 g per inhabitant put on the market, the collected quantity will be about 620 t, if the collection rate of 25% will be met.

Hazardous construction and demolition waste

In the draft Serbian Waste Management Plan for Hazardous Construction and Demolition Waste forecasts have been made for the quantities of hazardous construction and demolition waste gen-erated in 2020 in Serbia. The forecasts are based on the assumption, that the GDP of the construc-tion sector in Serbia will increase 5% annually. In addition, an assumed lack of reporting of 35% was taken into account. The results of the forecast are shown in Table 24.

Table 24: Forecast for hazardous construction and demolition waste.

Waste code Reported

Amount (t) 2014

Estimated Amount (t)

2020

17 01 06* Mixed C&D 2 4

17 02 04* Wood 202 365

17 04 09* Metals 8 14

17 04 10* Cables 37 67

17 05 03* Soil 1,812 3,278

17 06 01* Asbestos 6 11

17 06 03* Tar 89 161

17 06 05* Asbestos cement 103 186

Total hazardous 2,259 4,087

Total non‐hazardous 207,993 376,286

For the Serbian Waste Management Plan for Asbestos-containing Waste, estimations for the total

potential of asbestos waste generation in Serbia were accomplished based on the available data

on the apparent asbestos fibre consumption between 1930 and 2007 in Serbia. A quantity of ap-

proximately 45,000 t /y of asbestos wastes (mainly asbestos cement) was assumed. However, the

amounts of future yearly generated and reported asbestos containing C&D waste strongly depends

on the establishment of a proper waste management. For the prognosis of the future quantities a

maximal quantity of 40.000 t/a is taken as an estimation.

Hazardous combustion wastes

For the estimation of the future quantities of hazardous combustion wastes it is assumed that the quantity of this waste fraction will increase in line with the growth of GDP. For the growth of the GDP in Serbia a prognosis of the World Bank24 was used. According to this estimation the quantity of hazardous combustion wastes would in 2020 amount to 12,400 tonnes.

24 2016: 1,8%, 2017: 2,3%, 2018: 3,5%. Prognosis available at: http://data.worldbank.org/country/serbia#cp_gep


Secondary wastes from waste treatment

If new waste treatment facilities will be installed, more secondary hazardous wastes will be gener-ated. The future quantity of sludges and liquid wastes from waste treatment in 2020 was estimated based on the growth of the GDP, since relevant quantities were reported already for 2014. For hazardous sorting residues and mineral wastes from waste treatment and stabilised wastes a gen-eration rate of 1 kg per capita was assumed based on the data from other countries. The estimated total quantity of these hazardous secondary wastes would be 14,500 t.

Hazardous mineral wastes from mining and quarrying

The SEPA-statistics on waste generation included for the reference year 2014 about 155,000 t hazardous mineral wastes from mining and quarrying. These wastes from mining and quarrying are as of the reference year 2015 not anymore included in the SEPA-statistics on hazardous waste generation, since it is regarded that they are not covered by the Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC).

For the estimation of the future quantities of hazardous wastes it is assumed that about 60.000 t of such mineral hazardous waste will be generated in the sector of mining and quarrying, which have apparently hazardous properties and need to be treated in facilities covered be the Waste Frame-work Directive.

Hazardous wastes from households

The population of 7,1 Mio in Serbia is generating approximately 2,1 Mio tons of municipal waste per year. Corresponding to EU-28 statistics, some 4.000 to 8.000 tons are hazardous waste to be collected separately.

Contaminated soils

The estimation does not include amounts of excavated soils from future remediation activities, since a forecast of remediation activities is not available.


6.3 Summarizing illustration of the expected types and quantities of hazardous waste streams in Serbia


Table 25 presents a summarizing illustration of the forecast of hazardous waste generation in Ser-bia in 2020 broken down according to the substance-oriented waste categories defined on the ba-sis of the statistical European Waste Classification (EWCStat). The table is based on the extrapola-tions /estimations described in detail in Chapter 6.2.

It needs to be noted, that the forecast of hazardous waste generation includes 60,000 t of wastes from mining and quarrying which are allocated to the category “Other mineral wastes”. In the statis-tical European Waste Classification, asbestos wastes (forecast 40,000 t) are also allocated to the category “Other mineral wastes”.


Table 25: Expected types and quantities of hazardous wastes in Serbia broken down according to the waste categories defined in the European Waste Statistics Regulation (EC 2150/2002).

Waste category (EWC-Stat) Expected quantity of hazardous waste (t)

1 Spent solvents 1,699

3 Acid, alkaline or saline wastes 5,033

4 Used oils 22,316

6 Chemical Wastes (about 50% organic and 50% anorganic) 24,034

8 Industrial effluent sludges 7,850

10 Sludges and liquid wastes from waste treatment 699

12 Health care and biological wastes 5,000

17 Glass wastes 0

22 Wood wastes 466

24 Wastes containing PCB 84

26 Discarded equipment 13,800

28 Discarded vehicles 45,700

30 Batteries and accumulators wastes 18,000

36 Mixed and undifferentiated materials 3,952

38 Sorting residues 6,897

41 Mineral waste from construction and demolition 530

43 Other mineral wastes (asbestos + waste from mining&quarrying) 100,000

45 Combustion wastes 12,400

47 Soils 3,278

51 Mineral waste from waste treatment and stabilised wastes 6,897

TOTAL 278,635


7 ASSESSMENT OF NEEDS FOR NEW COLLECTION SYSTEM, ADDITIONAL INFRASTRUCTURE IN WASTE MANAGEMENT FACILITIES IN COMPLIANCE WITH SELF- SUFFICIENCY AND PROXIMITY PRINCIPLES, AND AS NECESSARY, INVESTMENTS INTOTHE CONSTRUCTION OF SUCH INFRASTRUCTURE

7.1 Options for the collection of hazardous wastes

7.1.1 Options for the collection of hazardous waste from industry and commerce

Collection of hazardous waste from industry and commerce (including the construction sector, the waste treatment sector and the medical sector) is usually carried out by private companies being li-censed for the collection/transport of particular hazardous wastes. Hazardous waste is either di-rectly taken to the treatment/recycling/incineration facility or transported to intermediate storage, of-ten owned by the collection and transport firms. In Serbia the collection and treatment of hazardous waste from industry and commerce will entirely be realized by the private waste management sector under the stringent regulatory framework of hazardous waste legislation. The sector of waste transport will develop step by step with the in-creasing demand of waste generators and treatment facilities. It is not the objective of this HWMP to plan the necessary transport capacities and equipment for the future. But it is the task of the regulatory and institutional framework to accompany the private waste transport sector to meet the legal, organisational and technical requirements. This means:

Any person who generates hazardous wastes repeatedly, at least once per year, has to report the type, quantity, origin of such wastes.

Any person who transfers hazardous wastes to another legal person (recipient) has to declare the type, quantity, origin and whereabouts of the hazardous wastes in a document of the movement of waste or, in the case of transboundary waste shipment, in a movement document as laid out in Annex IB of the EU Waste Shipment Regulation.

Any person who receives hazardous wastes for collection or for treatment has to report the type, quantity, origin and whereabouts of these wastes and the transport company. In the case of transboundaryshipment, the receipt of the waste has to be notified in line with the provisions of the EU Waste Shipment Regulation.

Any person who produces hazardous waste and treats it on-site by recovery or disposal opera-tions has to report the type, quantity, origin and whereabouts of such wastes by electronic re-porting. The same permits and licences are required as for any other waste treatment installa-tion where similar hazardous waste is treated.

Any person who collects waste (hazardous or non-hazardous) or treats it by recovery or disposal operations has to obtain a waste permit. They have to submit annual waste balances. The waste balances must contain information about the origin of accepted waste types, the relevant quantities and relevant whereabouts, including type and quantity of materials returned to the economic cycle, for the previous calendar year.


7.1.2 Options for the collection of hazardous waste from the construction sector

According to Article 35 of the Law on Waste Management hazardous waste has to be collected and transported separately. By that there is the obligation to avoid blending of hazardous and non haz-ardous wastes. In addition, in the draft by-law covering mineral C&D wastes obligations concerning the removal of hazardous substances before the demolition of buildings is proposed: Hazardous fractions (e.g. asbestos wastes) should be removed at the site of generation and kept separately until safe disposal in accordance with applicable regulation wherever feasible. If the hazardous components/materials cannot be removed before dismantling/de-construction the contamination of other material shall be kept to the minimum extent feasible.

In order to avoid blending of hazardous and non hazardous waste and to enable further recycling the collection and transport system for C&D waste has to take into consideration source separation (including the removal of hazardous materials/components) at the construction site. Therefore pos-sibilities for the collection and transport of specific hazardous wastes like e.g. asbestos containing wastes, PCB/PAH containing wastes, WEEE and lamps has to be established, which could be car-ried out by companies with respective permits.

In the draft Serbian Waste Management Plan for Hazardous Construction and Demolition Waste forecasts have been made for the quantities of hazardous construction and demolition waste gen-erated in 2020 in Serbia. It es assummed that about 4.000 t of hazardous construction and demoli-tion waste, need to be collected and treated in 2020.

Hazardous wastes which are source separated during demolition/de-construction at the construc-tion site should be stored at fortified areas. If classified as hazardous substances under ADR25, the wastes preferably should be stored in ADR-proofed big bags (e.g. asbestos containing waste. In general, dismantling, collection and transport activities of asbestos containing waste needs to be carried out by authorized and trained personal. Separated aerosol cans and paint cans may also be classified as hazardous substances under ADR and only be transported in suitable containers.

The owners of the hazardous construction waste shall be obliged to ask for assistance of special-ized enterprises to provide separate collection and temporary storing of this waste and have to bear the costs for the waste management. The collection and transportation of hazardous wastes from demolition/de-construction activities typically should be organized and be carried out by pri-vate sector (in case to be contracted by the owner of the building). In this context it is important that sufficient capacities for treatment of the different hazardous waste are in place to guarantee ade-quate environmental sound management of these waste streams. This private sector will develop step by step with increasing requirements of competent authorities to separate and collect hazard-ous construction and demolition wastes in an appropriate way.

Asbestos-containing waste is the most frequent and problematic category of hazardous construc-tion waste. It is expected that in the future up to 40.000 t of asbestos containing wastes have to be separated, collected and transported per year in Serbia. Asbestos presents a severe health risk when it is inhaled. Therefore, measures to protect health and the environment are to be taken, es-pecially during collection and transportation but not only when dealing with products containing weakly bound asbestos (e.g. sprayed asbestos). Weakly bound asbestos products can be found mainly in building insulation, furnishings and equipment. Therefore asbestos shall be separately collected during C&D activities, packed, stored and disposed, and the data about that shall be submitted to the competent authority. Technical protection measures comprise the collection of re-leased fibers at the point of origin by using a vacuum cleaner and the moistening of the affected area.

25 European Agreement concerning the International Carriage of Dangerous Goods by Road


Asbestos-containing waste shall be prepared for transportation and disposal by applying specific treatment techniques. Weakly bound asbestos waste must be packed in appropriate non-permeable certified packaging. At the moment there is no collection system for asbestos containing wastes in Serbia, the number of companies authorized to collect asbestos wastes will increase with increasing demand of the construction sector. The necessity of a more sustainable waste man-agement system in C&D waste management will accelerate this demand because asbestos ce-ment and weak bound asbestos hinder the success of C&D waste recycling. It could be helpful for the separation of asbestos wastes from other C&D waste in Serbia, that regu-lations lay down that prior to the demolition of a building it is obligatory to carry out an investigation of hazardous substances. An inventory of such materials should be drawn up, obligatorily. The building has to be deconstructed according to standard specifications laid down in national regula-tions. This should include an inspection for pollutants and impurities which hamper recycling. The owner of a building should be responsible that the inspection is performed by an expert in demoli-tion. An expert in demolition is a natural person, educated in construction or chemistry with knowledge in demolition works, waste chemistry, construction chemistry and waste management legislation. In bigger projects, authorised experts or expert bodies should be in charge of such in-vestigations; authorised experts or expert bodies are persons or institutions that carry out biologi-cal, chemical and physical tests under accredited conditions. The separation of hazardous waste (e.g. waste containing PCBs, PCPs-treated wood from demoli-tion) shall be required in order to comply with the POPs-order. But due to the small amount of rele-vant C&D compounds, this separation of fractions from demolition waste, especially separation of hazardous fractions such as PCBs fractions will be considered at a later stage in Serbia on the ba-sis of studies that are envisaged to be conducted. In any case, it must be stressed that with the en-tering into force of the Ministerial order on management of POPs waste, the proper disposal of POPs fractions will become legally binding. 7.1.3 Options for the collection of hazardous waste from the medical sector

The healthcare waste management chain comprises the following elements: Separation and storage at the point of generation.

Waste collection, internal transport and interim or central storage at health institutions level.

Transport and discharge of waste at transfer station.

Transfer and re-use or recycling.

Treatment and / or

Final disposal of waste.

The planning and realization of waste management within the health institutions can be left to the clinics which, as waste generators, have the obligation to elaborate healthcare waste management plans and take measures for their institutions. The Waste Management Act and the rulebook on healthcare waste management provide the legal framework for this and support is provided by the national institute for public health. (COWI & Euro Health Group 2013) For the short term, transportation of infectious waste from healthcare institutions to storage and treatment facilities shall continue to be performed by specialized facilities with corresponding per-mits while utilizing the vehicles donated by the European Union. (COWI & Euro Health Group 2013) For infectious waste transport needs will increase in the longer term. The more centralized ap-proach for the treatment of infectious waste in regional treatment facilities will require longer transport distances and optimization of the waste transport logistics. To be able to conduct trans-portation in an efficient and cost effective manner, larger transportation vehicles will be required and storage times at healthcare institutions will have to be increase. For this purpose, healthcare


institutions will ensure storage of infectious waste at temperatures below eight degrees Celsius. Transportation will be realized by the private sector. Pharmaceutical waste and, where practical, chemical waste shall be collected from healthcare in-stitutions, pharmacies and medical laboratories by private transport operators. These few private operators have been issued with permits to collect, transport and temporary store pharmaceutical and hazardous waste. They have also the experience and capacity to organize the export and treatment and disposal abroad. Once a small-scale incinerator facility has been realized the collec-tion and transportation of the pharmaceutical and chemical waste to the facility will be required. The same private operators will be able to conduct this task. The same applies to the transportation of pharmaceutical and chemical waste after the realization of the hazardous waste treatment facili-ty. (COWI & Euro Health Group 2013) A network for collection and treatment of medical waste generated in veterinary organizations should be established, i.e. it is necessary to use capacities of 12 veterinary institutes and procure additional necessary equipment.

For planning purposes a generated and collected quantity of 5,000 tons per year is used, which is assumed to remain constant for the planning period 2013 to 2025.

7.1.4 Options for the collection of hazardous waste from households

The future implementation of national legislation on separate collection and management of haz-ardous household waste has been recommended in connection with public awereness campaigns. Collection and intermediate storage of hazardous household waste is part of the integrated waste management activities of municipalities and therefore will evolve with the increasing engagement of Serbian municipalities in waste separation and collection activities. To achieve a successful collection of hazardous waste from households and small businesses, a mixture of some of the following collection options is considered as the most effective solution for the future: 1. Collection at civic amenity sites, where all kinds of wastes from households and small busi-

ness, including hazardous waste as spray cans, varnishes, pharmaceutical waste, waste oil, large WEEE, batteries etc. are accepted. Synergies in waste collection lead to reduced costs. These facilities are in most cases closed and fenced areas where containers for non-hazardous household wastes are placed. Hazardous wastes are collected in containers placed in houses or under a roof.

2. Stationary collection sites for hazardous waste additionally to the civic amenity sites; they pro-vide additional options to hand over low volumes of hazardous wastes households as batter-ies. These stationary collection sites for hazardous wastes are most often closed container houses where bins for different types of hazardous wastes are placed.

3. Mobile collection of hazardous waste also focuses on low volume hazardous wastes (gas dis-charge lamps, small screens, small appliances) as well. It focuses on rural regions without sta-tionary collection facilities. The mobile collection of hazardous wastes is performed with trucks, where containers for different hazardous wastes are placed at the loading area.

4. Take back at retailers is an option in particular for batteries, gas discharge lamps and waste oils. In several countries there is a legal obligation that “house-hold” amounts of waste oil and/or used oil filters have to be taken back at the point of sale free of charge.

5. Additional dedicated collection campaigns in cooperation with charity organizations for valua-ble hazardous waste, e.g. mobile phones can help making people aware of the collection top-ic.

All these options for collection have in common that handing over hazardous waste from household has to be free of charge for the citizens, in order to achieve high collection rates and to avoid con-tamination of recyclable fractions.


The quantity of hazardous waste arising from households (including packaging waste from paints, mineral oils, cleaning products, pesticides & fertilizers, pharmaceuticals products, etc.) represents only a very small percentage of the overall municipal waste stream, but the technical and personal equipment for this small amount of waste is relatively high. Therefore higher operational costs for this waste fraction are usual.

With regard to hazardous household waste, the municipalities or associations of municipalities should be obliged on a long term to carry out or organize a separate collection for hazardous household waste at least twice per year. The municipality should be obliged to determine certain dates and collection points for the collection of hazardous household waste. Dates and collection points have to be announced in a suitable manner and within due time. Civic amenity sites should be installed in bigger cities where hazardous household waste delivery should be free of charge. These sites have fixed business hours and are staffed with persons trained in the handling of haz-ardous household waste.

Separate collection of HHW may contribute to phasing out of POPs waste (e.g. old pesticides). A fee free collection system close to the households can prevent illegal disposal of such wastes. Synergies between the collections of packaging wastes, WEEEs, demolition wastes from house-holds, bulky wastes and HHW can be gained by introducing specific collection points/recycling yards. Based on the statistics of selected other countries, it is assumed that between 4.000 and 8.000 t of hazardous wastes from housholds will be separately collected in Serbia in the future. 7.1.5 Options for the collection of hazardous agrochemicals’ and industrial

packaging waste

Directive 94/62/EC on packaging and packaging waste and corresponding Serbian legislation are stipulating that all “persons involved in the production, use, import and distribution of packaging and packed products accept - in accordance with the polluter-pays principle - responsibility for such waste” assuring a maximum possible collection of packaging and packaging waste”.

As regards hazardous packaging waste a deposit system has been established in Serbia. Based on that provision, the Ministry adopted a list of different types of packaging containing chemicals for which the deposit system shall apply. The deposit system restricted to packaging of chemicals used with volumes exceeding 50 kg.should be applied also to smaller volumes.

Moreover, “the manufacturer and importer of chemicals shall, at their own expense, collect reusa-ble packaging and the packaging waste originating from such chemicals, from the seller”. Regula-tions state that “the seller shall accept from the user the reusable packaging and packaging waste originating from the substances in order to hand them over to the manufacturer or importer” and that “the user of chemicals shall return to the seller the used packaging and packaging waste”.

In case of hazardous waste generated in industrial processes, the responsibility for the organi-sation of the collection falls on the generating company which should find out the best methods to recover and recycle their waste. The largest quantities of hazardous packaging waste come from five sectors: chemical and pharmaceutical manufacture, metals refining, petroleum and coal prod-ucts, metal working and fabrication, rubber and plastics manufacture. Smaller quantities are com-ing from chemical, construction industry, vehicle maintenance shops, furniture & wood manufactur-ing and refurbishing.


In case of hazardous packaging generated in agricultural processes, the agrochemical indus-try should take the responsibility to manage their hazardous packaging waste through nation-wide separate collection schemes. At present, the agrochemical industry is carrying out a market as-sessment in order to identify the most efficient and cost effective way of achieving the responsibili-ties.

It can be assumed, that the industry is in favor of having agro-packaging and industrial packaging collection systems run under their control, according to precisely described conditions. However, the Serbian industry is faced with the lack of treatment facilities within the country and thus the hazardous packaging has to be exported for treatment, which will be at a higher cost. Thus, pro-ducers are using intermediate storage facilities followed by export. This is also the case for primary packaging waste from the crop protection products, which are not managed either individually or within any collective scheme. An innovative approach could be voluntary agreements in the field of packaging resulting from the agriculture processes. Consequently, the producer responsibility prin-ciple is implemented in a smoother way without imposing coercive measures upon the industry from competent authority’s side.

Chosen schemes should avoid direct charges to commercial and agricultural users for returning containers. The locations to which such users may return empty containers should be convenient and avoid additional travel; European experience shows that best results are achieved by pick up on demand systems. No quantities and no prognostic amounts for hazardous packaging waste are available at present. 7.1.6 Options for the collection of waste oils

The collection of waste oil and other oil wastes usually comprises the separation and collection at the point of generation and the further collection by a waste collector. With proper separate collec-tion and storage of waste oil fractions a certain degree of homogenization and pre-cleaning can al-ready be achieved. In order to facilitate environmental sound and also economically feasible treat-ment and use of waste oil and other oil wastes, various technical requirements regarding storage and transport have to be considered. According to the forecast presented in chapter 6.approximately 25,000 tonnes of waste oil are ex-pected to be provided to the official waste treatment sector in the near future. Furthermore, with implementation of increasing environmental standards in Serbia, e.g. by widely used oil/water sep-arators at petrol stations, garages etc. relevant additional amounts of oil containing wastes from these installations will be generated. Implementing strict measures for complete collection of waste oil in households and garages, the quantity could increase even more. Thus, further capacity for collection and transport will be required in Serbia. . , For the collection of waste oil from house-holds the following options exist:

Collection/take back at final sellers

Collection at civic amenity sites, taking over all kinds of wastes from households and small busi-ness, has the major advantage that synergies in waste collection are used leading to reduced costs for collection.

Stationary collection sites for hazardous waste (focusing on low volume hazardous wastes) pro-vide additional options to hand over ‘hazardous wastes’.

Mobile collection of hazardous waste focuses on low volume hazardous wastes (gas discharge lamps, small screens and small appliances) as well. The disadvantage compared to stationary collection of hazardous waste is higher costs.


Collection of waste oil and other oil waste from the industrial and commercial sector (and from collection sites for private end-users) is usually carried out by private companies being licensed for the collection/transport of oil wastes. The waste oil is either directly taken to the treat-ment/recycling/incineration plant or transported to intermediate storage.

The persons that conduct collection, storing and treatment of waste oils must have a permit, must maintain and keep records and report relevant data to competent authorities. For certain quantities of halogenated waste oils (incl. PCB) and waste oils with a relevant content of other hazardous wastes (e.g. due to specific chemical formulation or accidental or intentional mixing) exporting for treatment in appropriate facilities may still be required in the future. On a medium term, reception points for waste oils collection should be established, as well as a sound collection and treatment system covering 100% of waste oil and waste oil emulsions. Pre-conditions must be established for a retailer who sells oils for motor vehicles to provide conditions in the sales outlet for taking over waste oils from end-users who purchase motor oils from him; a retailer must keep them until they are taken over by a collector, in compliance with environmental protection. Filling stations, automobile mechanics, engine service stations, mineral oil trading companies and companies supplying motor oils to end consumer should be obliged to take back the same amount of waste motor oil as fresh motor oil has been sold to this end consumer. No fee should be charged for the oil filters, neither. On a long term, priority should be given to re-refining waste oil i.e. the production of basic oil (un-less the limit value of PCB does not exceed 20 mg/kg). In order to avoid contamination of refined secondary basic oils, a further main requirement of this regulation must be a general prohibition to mix waste oil with other wastes, with PCB-waste oil or waste oil of various collecting categories. Therefore waste oil collectors and recovery installations shall take and store samples of waste oils and the installations shall analyse these waste oils concerning PCB and summary halogenated contents and declare the determined concentrations.


7.1.7 Options for the collection of hazardous waste streams covered by extended producer responsibility systems

7.1.7.1 Options for the collection of waste batteries and accumulators

Used batteries and accumulators are classified as hazardous waste. They should be collected, sorted and prepared for separate treatment according to the battery chemistry types. The classifi-cation according to battery chemistries, which is presented in the table below,is useful to give in-formation on specific collection and storage requirements. In this context, an additional differentia-tion between batteries containing liquids and batteries without liquids is useful, as well.

Table 26: Classification of batteries and accumulators according to battery chemistries.

Collection and sorting fraction with liquids

Pb-acid accumulators - liquid including sealed lead acid accumulators with non-fixed elec-trolyte

Ni/Cd accumulators – liquid mainly industrial batteries Collection and sorting fraction without liquids

Pb accumulators in sealed accumulators; the electrolyte is fixed by adding silica gel or by using a fibreglass mat

Ni/Cd accumulators mainly consumer batteries, cellular phone batteries

NiMH consumer batteries, power packs

Li-ion power packs, cellular phone batteries

Li-primary, metallic Lithium button cells and specific forms of consumer batteries

button cells (other) sometimes containing silver or mercury

AlMn / ZnC / ZnO mainly consumer batteries From a practical point of view, waste lead batteries and accumulators, generally from automotive sector should be distinguished from all other batteries and accumulators: Batteries and accumulators with free liquid electrolyte may cause specific damage during storage and transport. They shall be kept separately based on the nature of their electrolyte (acidic, alkaline or organic) and stored in tight, leak proof and stable containers. Sealed batteries/accumulators are normally not regarded as batteries with liquid electrolyte. However, sealed lead acid batteries should be regarded as accumulators with liquid electrolyte since the acid may leak out quite easily due to mechanical damage. It is therefore recommended to collect, store and transport seal lead acid batteries in the same way as normal lead acid batteries. Most recycling processes for lead ac-id batteries do not require a separation of sealed accumulators and accumulators with fixed electro-lyte from accumulators containing a liquid electrolyte. It is not recommended to drain of liquid elec-trolyte/battery acid before shipping the batteries to the recycling facility.

Li-batteries (primary batteries) and Li-accumulators (secondary batteries) pose a high risk for the environment and for human health during waste collection, transport and treatment. Primary Lithi-um batteries in most cases contain Lithium in metallic form. Additionally aggressive chemicals may be used as cathode material. Mechanical damage of the sealing of a primary battery may lead to self-ignition and/or the release of aggressive substances. Furthermore a short-circuit fault may re-sult in battery explosion since the discharge curve has a negative temperature coefficient. Most of the secondary lithium batteries do not contain metallic Lithium but an intercalation compound of Lithium with either graphite or a transition metal oxide. These batteries are less reactive than me-tallic Lithium batteries.


NiMH batteries pose a higher risk of self-indignation than other secondary batteries. If NiMH batter-ies are stored together with other types of batteries the risk of short circuits is enhanced. Therefore, special type NiMH batteries should be collected/sorted in restricted amounts only, fit for direct transport. Since an explosive hydrogen air mixture may be generated due to leakage of one or more cells within the container, the container shall be grounded before manipulation. According to EU Batteries Directive (2006/66/EC) storage, including temporary storage, of waste batteries at treatment facilities shall take place in sites with impermeable surfaces and suitable weatherproof covering or in suitable containers. These specifications are valid for storage at treat-ment facilities including sorting facilities and storage facilities The limit of 2,5 tons in the EU Batter-ies Directive as the threshold for requiring a dedicated storage building may be applied to collection facilities like stores, car repair centres etc. where batteries and accumulators are taken back from final users. In these facilities batteries and accumulators are stored until a pick-up service trans-ports them to treatment facilities. The interim / small scale storage for portable batteries and accumulators has to fulfil technical re-quirements such as suitable containers are to be used

all storage areas have impermeable surfaces

the storage building and/or the outdoor storage area are covered with a roof

the storage building or area is inaccessible for unauthorised person.

At the moment, the biggest part ofd discarded lead acid accumulators is exported from Serbia to recycling. Expected quantities in chapter 6 of this HWMP indicate, that the quantity of lead-acid ac-cumulators generated and collected will be about 18.000 t in 2020. Concerning other (portable) batteries and accumulators, some 350 to 620 tons per year are ex-pected for collection. At present, these used batteries end up with household waste in municipal waste dumps. The exported amount of portable batteries and accumulators is also low (several tonnes per year). Logistics for separate collection and sorting capacities will be needed. Collection schemes for batteries and accumulators both in the legal provisions and in reality are missing in Serbia till now. According to the Directive 2006/66/EC, however, appropriate collection schemes for waste portable batteries and accumulators and automotive batteries and accumulators have to be in place. Collection schemes have to ensure accessible collection points in the vicinity of the end-users on the one hand. On the other hand there is the obligation of the distributor to take back waste portable batteries and accumulators at no charge. It is also necessary for producers of automotive batteries and accumulators to take them back from end-users without charge. Also for this reason schemes for the collection of waste are to be set up. The implementing legal act has to ensure that producers of industrial batteries and accumulators shall not refuse to take back waste industrial batteries and accumulators. Several operators of WEEE treatment plants already expressed their interest in the collection and treatment of portable batteries and accumulators. On a mid term, a closed collection and recovery system (collective scheme), for portable batteries should enclose a system of taking back spent portable batteries at the point of sale by means of collection boxes. This take back system for consumer batteries should work completely on a volun-tary basis. On a long term, take back obligations should be extended to portable batteries and ac-cumulators incorporated in electronic appliances. Collection points for batteries and accumulators should be determined, and the consumers should be encouraged to separate used batteries and accumulators from municipal and other types of waste and to deliver them to these points. Labelling of batteries and accumulators must be implemented by using labels that include instruc-tions and warnings for separate collection, contents of heavy metals, possibility of recycling or dis-posal, etc.


National targets for collection of batteries should be determined. The Batteries and Accumulators Directive (2006/66/EC) requires the following targets to be met: a 25% collection rate for waste portable batteries to be met by September 2012, rising to 45% by September 2016.

With respect to economic instruments, the payment of fees for producers and importers of batteries and accumulators shall be used for collection and treatment of such waste. A person that conducts collection, storing and treatment of used batteries and accumulators must have a permit, must also maintain and keep records on used batteries and accumulators and the collected, stored and treated quantities, and must report relevant data to the competent authority. 7.1.7.2 Options for the collection of WEEE

Waste electrical and electronic equipment (WEEE) is composed of waste household devices (TV sets, radios, refrigerators, freezers, etc.), personal computers, telephones, cassette recorders, etc. Most of this waste is hazardous waste because of the components it contains. The WEEE Di-rective (2012/19/EU).classifies EEE into 6 groups: Group 1 – temperature exchange equipment (refrigerators, freezers)

Group 2 – screens and monitors with surface greater than 100 cm2

Group 3 – lamps

Group 4 – large equipment (any equipment, except for groups 1-3, at least one dimension of which exceeds 50cm)

Group 5 – small equipment (any equipment, except for groups 1-3, which none of dimensions exceeds 50cm)

Group 6 – small IT and telecom equipment (none of dimensions exceeds 50cm)

The WEEE Directive (2002/96/EC) defined a minimum collection target of 4 kg/cap/yr from private households. The recast of the WEEE Directive (Directive 2012/19/EU) foresees that from 2016 to 2018 Member States have to collect 45% of the total mass of EEE put on the market and as of 2019 65% of the total mass of EEE put on the market. . The system for separate collection of electrical and electronic products should be established so that the usable parts could be recycled. The waste components of electronic and electrical prod-ucts containing PCB must be hold separate and their appropriate disposal must be ensured. It is also necessary that a separate recovery of refrigerants should be established. According to the forecast presented in chapter 6, between 20.700 t and 27.600 t of WEEE are ex-pected to be separately collected in the near future. Currently, the separate collection of WEEE from businesses in Serbia is predominantly conducted by the operators of WEEE treatment plants themselves. It is assumed that a high collection rate of most types of WEEE from businesses will be achieved, even without implementing any additional measures. It can be assumed that no regular collection system for WEEE from households and small busi-nesses exists for the moment and that a relevant part of WEEE from households is collected by in-formal collection activities,


To achieve a successful collection of WEEE from households and small businesses, a mixture of some of the following collection options is considered as the most effective solution: Collection of all types of WEEE at civic amenity sites, where all kinds of wastes from households

and small business are accepted. Synergies in waste collection lead to reduced costs. These facilities are in most cases closed and fenced areas where containers for non hazardous household wastes are placed, most of them are placed under shed roof. Hazardous wastes are collected in containers placed in houses or under a roof.

Stationary collection sites for hazardous waste (focusing on low volume hazardous wastes) pro-vide additional options to hand over ‘hazardous wastes’. Regarding WEEE, usually gas dis-charge lamps, screens and small appliances are collected. These stationary collection sites for hazardous wastes are most often closed container houses where bins for different types of hazardous wastes are placed.

Mobile collection of hazardous waste focuses on low volume hazardous wastes (gas discharge lamps, small screens, small appliances) as well. The mobile collection of hazardous wastes is performed with trucks, where containers for different hazardous wastes are placed at the load-ing area.

Mobile collection of bulky waste provides additional options for the delivery of large appliances in particular for people not having a car. Two options exist: pick-up service on demand or pick-up service at fixed dates, which are usually communicated via communal newspaper or in the in-ternet.

Collection/Take back at retailers and

Dedicated collection campaigns in cooperation with charity organizations for valuable WEEE, e.g. mobile phones can help making people aware of the collection topic.

A combination of collection of WEEE and other types of wastes (HHW, bulky waste, packaging, etc.) at municipal collection centres is not only favourable in terms of cost effectiveness but also for the consumers. To reach high collection rates, additional collection avenues can be helpful: Collection of small WEEE in shopping centres

Mobile collection

Collection at multi-family dwellings

Curb side collection

Collection of mobile phones as a valuable waste stream

In general, collection of WEEE requires storage under weatherproof covering and on impermeable – oil and solvent resistant - surfaces. Surface waters and any leakage must be directed to a drain-ing system or to a collecting container from where they can be removed. For different WEEE-categories different collection and transportation containers are required, be-cause of different environmental risks when handling them. Cooling and freezing equipment usually is secured against slipping by putting it rather tight and

in an upright position into containers. If the equipment is transported upside-down or lying on parts of the refrigeration circuit, the cooling circuit may be damaged which bears the risk of re-leases of compressor oil or chlorofluorocarbons (CFCs) etc. For transportation usually closed steel containers are used.

Damage of gas discharge lamps has to be avoided to prevent emissions of mercury. For secure transportation of straight gas discharge lamps post pallets or closed metal boxes turned out to be appropriate. Gas tight containers are required for storage and transport of broken lamps.


There are no data on the quantities of the waste fluorescent tubes. In RS there is no separate collection of these tubes. They are, together with the municipal waste, disposed in the landfills.

To prevent damage of screens (cathode ray tube appliances and flat screens), transportation in lattice boxes, in closed pallet boxes or on pallets fixed with plastic films is applied.

Common for collecting any small appliances are lattice boxes or pallets with foil (e.g. for PCs). Large household appliances are often collected and transported in larger steel containers.

The Serbian Waste Management Acti prohibits the mixing of WEEE with other waste and the dis-posal of WEEE without adequate pre-treatment. The persons taking over WEEE shallissue and keep a takeover certificate, as well as the certificate of their dispatch for treatment or disposal. The person performing collection, treatment or disposal of WEEE must hold a permit, keep records of the quantity and type of electrical and electronic products taken over and submit those data to the competent authorities. There is still a lack of some essential provisions necessary for establishing a functioning WEEE management system in Serbia. Detailed rules how producers/importers have to comply with their obligations or delegate all their obligations need to be established. 7.1.7.3 Options for the collection and management of ELVs

According to Article 5(1) of the ELV Directive (2000/53/EC) Member States should take the neces-sary measures to ensure that producers/operators set up systems for the collection of all ELV and, as far as technically feasible, of waste components removed from ELV and the adequate availabil-ity of collection facilities within their territory.The ELV Directive (2000/53/EC) has been largely transposed through the Serbian Law on Waste Management and the Rulebook on the manner and procedure of end-of-life vehicles. Full transposition is anticipated by 2018 at the latest. In Serbia there are around 1 million vehicles whose average age is more than 10 years. The take-back system for end-of life vehicles is explicitly required to be cost free for the consum-ers. The first steps in the ELV processing chain is an automobile’s declaration as an ELV, deregis-tration and issuance of a destruction certificate. The collection and handling of vehicles declared ELV usually comprises the transfer of the car to a designated treatment facility where the actual depollution, dismantling and recycling pro-cesses take place. Collection facilities only take back the vehicles and forward them to dismantling facilities, which have to issue immediately a certificate of destruction, when they receive an ELV. Collection and management of ELV depends mostly on supply and demand. At the moment, the quantities of ELV reported to SEPA seem to be too low. This means, traders not yet properly fulfil their reporting obligations. Moreover, it can be assumed, that ELV are often collected by informal collection activities, with the aim to sell separated parts and scrap metal for recycling. ELV might also be shipped abroad informally, or by private persons, defined as products and so far escaping from the waste legislation. According to the forecast presented in chapter 6, about 45.700 t of end-of-life vehicles are expected to be collcted in 2020. In accordance with the ELV Directive (2000/53/EC) it is possible for producers to fulfil their take-back obligations individually. However, it is also possible to use ELV management options through voluntary agreement. The ELV Directive (2000/53/EC ) might allow several options for the car owner to give back his ve-hicle. Official take-back points of the producers/importers,

Car dealers, which are not producers/importers, e.g. in connection with buying a new car and

Collection or treatment companies, which are not part of the collective system.


Last holder of vehicle should be obliged to pass it to dismantling facility with a permit or to ELVs collection points in order to de-register the vehicle. These ELVs collection points have to establish a contract with dismantling facilities being licenced as well. Dismantling facility on the other hand are obliged to accept ELVs without imposing any charges. With respect to economic instruments, the payment of fee for producers and importers of vehicles shall be used for the collection and treatment of this waste. 7.1.8 Options for the collection of PCB waste and other wastes containing POPs

PCBs and PCB waste management is regulated by Article 52 of the Serbian Waste Management Act. According to this Article, PCB waste shall be collected separately. It is foreseen that in Serbia equipment containing more than 5 dm3 of PCB will be disposed of or decontaminated until 2019/20 at the latest. Equipment containing between 0.005% and 0.05% by weight (equivalent to 500 ppm or 500 mg/kg) of PCBs shall be decontaminated or disposed of when it is out of use. The Serbian Waste Management Actdefines obligations of the PCB owners concerning the man-agement of PCB waste or PCB-containing equipment: the owner of PCB and PCB waste is obliged to organize its disposal, i.e. decontamination;

the owner of PCB-containing equipment in use or an equipment possibly contaminated with PCB, is obliged to examine the PCB content using the services of accredited laboratory author-ized to conduct such waste analysis;

the owner of equipment containing more than 5 dm3 of PCB is obliged to report to the MEMSP and to propose a replacement plan, i.e. a plan of its disposal and decontamination, to ensure its disposal and decontamination, as well as to report to the MEMSP any change of data relat-ed to equipment, not later 3 three months from the date when the change has occurred.

There is no facility for PCB waste treatment in Serbia and currently this waste is exported for treatment. The inventory, storage and final disposal of PCBs contaminated equipment and waste are defined in the Action Plan for PCBs within the National Implementation Plan and will be improved by fur-ther projects concerning environmentally sound management and final disposal of PCBs. The pro-ject Environmentally Sound Management and Final Disposal of PCBs will establish the basis for decisions concerning whether to develop installations for the disposal of PCBs and contaminat-ed equipment in Serbia and to choose the best solution for disposal of Serbian PCB waste and contaminated equipment. Due to lack of treatment facilities for hazardous wastes, also other POPs waste are presently stored in intermediate storage facilities prior to export to adequate disposal facilities (hazardous waste incinerators) abroad. Some of the intermediate storage facilities for POPs waste are inade-quate (“factory-storage”) and do not comply with the-state-of-the-art. This especially refers to POPs waste, whose owner is not always known. The POPs waste, which presently is stored in inade-quate intermediate storage facilities should be transferred to suitable intermediate storage facilities; in this context inspections and repackaging of obsolete pesticides should take place. In general suitable solvent-resistant troughs/tanks should be used during storage and transport. Temporary storage facilities should be adjusted to the-state-of-the-art as soon as possible. The establishment of new storage facilities complying with the-state-of-the-art (maybe state-owed) should be consid-ered POP-contaminated soils have to be identified and remediation has to take place in an environ-mentally sound manner. Locations where chlorinated organic pesticides were produced in the past, areas characterized by the use of PCBs-containing equipment and industrial processes generating PCDD/PCDF and PAH releases, chlor-alkali facilities, facilities having used vinyl chloride mono-mers and chlorinated phenols (wood protection, leather tanning) stand the risk of contamination with POPs and require comprehensive investigations; the same applies to locations where pesti-


cides POPs were handled or stored or disposed in the past (local dump sites). Contaminated soil, exhibiting more than 10,000ng PCDD/PCDF-ITEQ/kg (e.g. resulting from bombardment and burn-ing of PCBs transformers) or soil contaminated with PCBs is exported as HW for the purpose ap-propriate treatment. There are still a lot of “hot spots” of contaminated areas in Serbia. The Serbian legislation on Cleaning-up of Contaminated Soil (i.e. mainly the Law on Environmental Protection and the Decree on “Systematic soil quality monitoring programme, indicators for as-sessment of risk of soil degradation and methodology for establishment of remediation pro-grammes”) needs further improvement with regard to responsibilities of authorities for clean-up programmes and the financing of the measures. In order to raise money for sanitation of aban-doned contaminated sites the introduction of a fee for waste disposal could be envisaged, which should be earmarked (at least to some extent) for financing of clean-up of abandoned contaminat-ed sites. 7.1.9 Transboundary shipment of hazardous waste

According to the National Program for Adoption of the Acquis (NPAA), the full alignment with the Waste Shipment Regulationwill be achieved in 2018, by revision of by-laws regarding transbounda-ry movement of waste. The international agreements and the implementation of the obligations of the Waste Shipment Regulation (Regulation (EC) No. 1013/2006) guarantee a transparent and universal administrative procedure for Serbian waste owners and aa worldwide network of available and appropriate treat-ment plants for wastes which cannot be treated in the own territory. Waste generators can use these capacities if available and if authorized by competent authorities of all countries concerned (country of origin of waste, country of transfer and country of treatment and disposal). Special conditions on inspections are laid down in Article 50 of the Waste Shipment Regulation (Regulation (EC) No. 1013/2006) . According to this, the inspection of shipments have to be planned according to a risk profile concerning mainly affected waste streams, transport routes and involved persons (notifies, waste generator, transporter, waste plant operator).

7.2 Options for the treatment, recovery and disposal of hazardous wastes

Hazardous waste management facilities are only a small but relatively expensive portion of a com-plete integrated waste management infrastructure. The boundaries between hazardous and non-hazardous waste management infrastructure are blurred and facilities for non-hazardous and haz-ardous waste depend from each other. Investment in hazardous waste management facilities should therefore be seen as an integral and indispensable part of a complete waste management infrastructure. Currently, the insufficient infrastructure for treatment and disposal of hazardous waste makes a serious problem of appropriate waste management in Serbia. Construction of facilities for hazardous waste treatment is therefore one of the priorities of the Gov-ernment of Serbia, which is underlined in the Council Decision on the principles, priorities and con-ditions contained in the European Partnership (2008/13/ЕC). Existing capacities in industry (ce-ment kilns, steel blast furnaces and electrical power plants) for thermal treatment and energy re-covery from waste could be utilized more effectively in the future. Permitting All adaptions of existing facilities and the establishment of new treatment and disposal plants need a permit which follows the licensing procedure driven by the competent authorities.


Serbian legislation defines the requirements of two licensing procedures: 1. An extended licensing procedure mainly for plants which are part of the European Industrial

Emission Directive (2010/75/EU) and for plants which are identified as plants under the scope of European Seveso-Directive and

2. a simplified licensing procedure mainly for other industrial plants. All licensed waste management plants are subject to the inspection (supervision and control) by the competent authority. These inspection measures should be realized according to the principle that the competent authority for licensing shall be responsible for the inspection, as well. Depending on the technology applied, the hazardous character and the quantity of waste treated, future Serbian installations for hazardous waste treatment and disposal might have to fulfil the con-ditions of IED installations and therefore apply the regulation of the European Industrial Emission Directive (2010/75/EU). A permit for an IED-plant shall be granted, if the plant fulfils the following requirements:

1. All suitable and economically proportionate measures to prevent environmental pollution have been taken, in particular with the use of methods, equipment and operating modes in accord-ance with the state of the art.

2. Energy will be used efficiently. 3. The necessary measures will be taken to prevent incidents and to control their environmental

and health impact. 4. Necessary measures will be taken to prevent the hazard of environmental pollution after liqui-

dation of the treatment plant, and to restore a satisfactory state of the treatment plant site, if necessary.

All IED plants have to be inspected on the basis of a supervision plan (currently elaborated and re-leased by the Ministry) and a supervision program for each single plant (elaborated by the compe-tent authority). The supervision plan defines criteria for the assignment of plants to the regular and minimum supervision periods (once every 1, 2 or 3 years) depending on individual risks. Besides these regular inspections, further occasional inspections shall be carried out by the authority in case of start-up or closing of plants, of illegal states or illegal operation procedures and of public complaints about the plant. If an occasional inspection is carried out, a follow-up is needed in order to check if the measures imposed to the operator have been realized. The legislation on licensing industrial plants requires the operator to fulfill the state-of-the-art which is defined through Best References Documents (BREF) released by the EU. For waste manage-ment plants, the authority is obliged to raise a financial security/guarantee. For other industrial plants the authority can raise a respective financial guarantee. Mobile treatment plants should be limited mainly to cracking, shredding or sorting mineral residues in construction and demolition measures in situ i.e. in the site of generation of the waste and should be limited in time.


According to Serbian WMA the following information shall be enclosed with the application for au-thorisation of a waste treatment plant: 1. information about the suitability of the intended site; 2. information about the form, purpose, scope and duration of the project; 3. the land register identification of the property affected by the treatment plant, indicating the

name of the owner and enclosing an extract from the land register that is not older than six weeks;

4. the written consent of the property owner on whose property the treatment plant is to be estab-lished, if the applicant is not the owner;

5. statement of water rights legally exercised by the owner; 6. a description of the operation, including information about the types of waste to be treated, the

treatment methods, and a list of machinery and other plant equipment; 7. construction specifications with the necessary designs and drawings; 8. description of the anticipated wastes that will accumulate during operation of the treatment

plant and measures for their prevention, recovery or disposal (waste management concept); 9. description of the anticipated emissions from the treatment plant and information about the

prevention or, if this is not possible, reduction of emissions.

The application for authorisation of an IEDtreatment plant shall be made public in two daily news-papers of high circulation in the province concerned. The publication shall indicate that the applica-tion shall be available for consultation during the office hours of the authority for a specified period of at least six weeks, and that any person may comment on the application during this period.If the IED treatment plant could affect a neighbouring country, the authority shall inform this country about the project.


Scheme of future hazardous waste management in Serbia The Scheme of a possible future hazardous waste management in Serbia is shown below. It con-sists of: decentralized or central storages for the collection and storage in order to prepare for transport,

physical-chemical treatment plants for liquid and pasty hazardous waste (sludges) ,

incineration plants for waste with hazardous organic compounds,

hazardous landfills for mineral or mineralized hazardous waste and

mechanical treatment and dismantling plants, where recyclable materials are separated from hazardous components to be disposed of otherwise.

Certain elements like the incineration plant might be replaced by existing thermal facilities like ce-ment plants. Hazardous landfills might be integrated into sanitary landfills as independent cells with higher technical standard.

Figure 9: Scheme of future hazardous waste management in Serbia


7.2.1 Available treatment, recovery and disposal technology for hazardous wastes

7.2.1.1 Landfilling of Hazardous waste

Landfills are necessary elements of all sustainable waste management systems, because after any treatment certain residues must be disposed of. European and Serbian legislation define three types of landfills for waste disposal, each related to threshold values of waste characteristics to be accepted and combined with geological, technical and organizational requirements. Depending on this landfill “class”, the requirements on basement systems, landfilled waste, covering sealing sys-tems, water management systems, re-cultivation strata etc. are determined as state-of-the-art in landfill technology. The three landfill types or “classes” are:. landfills for disposing of non-hazardous waste;

landfills for disposing of inert waste;

landfills for disposing of hazardous waste,

Underground storage facilities are a fourth type of waste disposal which is - due to geological con-ditions - not applicable in some countries and often submitted to Mining regulations. Council Deci-sion 2003/33/EC26 also contains specific provisions for permanent underground storage. These provisions are fully implemented in Serbia. Article 6 of the Landfill Directive stipulates which wastes must be deposited on which class of landfill. The threshold values for the different types of landfills as set out by Council Decision 2003/33/EC are transposed in the Ministerial Orders on waste clas-sification.

Hazardous waste landfills are envisaged for the disposal of hazardous waste, designed with spe-cial technical requirements. Hazardous waste disposed in these landfills must be pre-treated in ac-cordance with Landfill regulations and regarding the above mentioned principles as well. The Council Decision 2003/33/EC is widely implemented by the Ministerial Orders on classification of waste, especially the limit values for classifying a waste as hazardous. It should be foreseen in Serbia to create special compartments on existing landfill sites that fulfil prescribed underground conditions to be dedicated to landfilling of hazardous waste. Provisions and requirements referring to hazardous landfills shall apply to such compartments. Certain types of hazardous wastes (e.g. asbestos and some other hazardous wastes from con-struction and demolition) can be disposed of in special cells for hazardous wastes on landfills for non-hazardous wastes. An essential part of requirements concerning environmentally sound waste disposal in hazardous landfills has been laid down in the so called waste acceptance procedure (Article 11 of the Landfill Directive), which implies stringent pre-treatment techniques before disposal. It is a three step ap-proach to control landfilled waste: 1. Beginning with a classification of a waste at its source underlined by laboratory testing and

annexed to the contract between the generator and the treatment facility owner, approved by the competent authority. Additionally, there are procedural provisions on record keeping, issu-ing receipts for acceptance of waste, etc.

2. A movement document for each transport of waste accompanied by the related contract num-ber helps to identify the waste moved and the legal status of the movement.

3. Control and monitoring procedures during the operational phase: these provisions require to secure a close monitoring of the landfill and its operation by qualified experts/laboratories. The provisions on monitoring comply with the obligations under the landfill permit. The qualification of the monitoring expert is secured by the MO on waste classification.

26 Council Decision of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills

pursuant to Article 16 of and Annex II to Directive 1999/31/EC


Serbia has transposed the Landfill Directive (1999/31/EC ) through the Waste Management Act and Governmental order on disposal of waste in landfills. They are supplemented by two Ministerial Orders (MO): The Rulebook on categories, testing and classification of waste sets out the more detailed re-

quirements for waste acceptance criteria, and

the Rulebook on application and content of a permit for storage, treatment and disposal, trans-posing some elements of the Directives’ requirements for landfill permit application, conditions and content

Several articles of the Landfill Directive (1999/31/EC ) will be transposed by amendments to the Governmental order on disposal of waste in landfills by 2018. The exact mechanism for full trans-position will be determined as part of the revision of the National Waste Management Strategy. It will be a matter of negotiation with the Commission to determine targets, dates and adequate tran-sitional period (e.g. the ultimate deadline for Serbian closure and remediation of existing dumpsites/landfills).

A certain novelty for Serbia are the closure and aftercare procedures laid down in Article 13 of the Landfill Directive: (1999/31/EC ). This article regulates the conditions for starting the close down procedure as foreseen in the landfill permit. The procedure may be triggered by conditions in the permit, by the competent authority or by the operator of the landfill. National legislation may provide general rules for this trigger. It should be mentioned that the Landfill Directive sets the period of 30 years for after-care as a minimum period. Article 14 of the Landfill Directive: (1999/31/EC ) allows and stipulates the procedure to adapt exist-ing landfills to the new standards of the Landfill Directive. Based on the obligation in the Serbian Waste Management Act that all the operators of existing waste management facilities in general have to notify the competent authority within 6 months after the entry into force of the law about the facility and the technical operations they perform. The competent authority may then renew the permit taking into account changes in the regulations and the adaption to the state-of-the-art in landfill technology. This clause may be used either to adapt existing landfills to the state-of-the-art or close them down (by not renewing the permit). 7.2.1.2 Incineration of hazardous waste

At EU level waste incineration used to be regulated mainly by the Waste Incineration Directive (2000/76/EC). The waste incineration legislation in Serbia, namely the Law on Waste Manage-ment (Waste Management Act, WMA) and the Governmental order (GO) on conditions, method and procedure of thermal waste treatment, are largely in compliance with Directive 2000/76/EC. Meanwhile, the Waste Incineration Directive (WID) has been recast within the Industrial Emis-sions Directive (2010/75/EU)as of December 2010. The purpose of this was to transpose several pre-existing directives on the control of emissions from industrial processes into one directive on industrial emissions. Directive 2010/75/EU on industrial emissions (IED) entered into force on 6 January 2011. With the entering into force of this Directive, on the one hand, the scope of the existing legislation is ex-tended to include additional activities such as combustion plants of between 20 and 50 MW, pro-duction of wood-based panels and protection of wood, and on the other, it is clarified that certain activities already covered by the existing EU legislation, such as waste treatment and food produc-tion are also covered by the IED respectively former IPPC legislation. In addition, the new directive improves and clarifies the concept of the BATs.


The following incineration installations fall under the scope of the IED: the incineration or co-incineration of non-hazardous waste with a capacity exceeding 3 tonnes

per hour

the incineration or co-incineration of hazardous waste with a capacity exceeding 10 tonnes per day

In addition to the co-incineration of waste, the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or in other kilns with a production capacity exceeding 50 tonnes per day also falls under the scope of the IED

On a national level, all detailed requirements to waste incineration are provided in the Governmen-tal order on conditions, methods and procedures of thermal waste treatment adopted on the basis of Article 41(7) of the Waste Management Act. It was adopted on 23 December 2010. It de-fines the types of waste for which thermal treatment is conducted, conditions and criteria for deter-mining the location, technical and technological conditions for designing, constructing, equipping and operation of facilities for thermal treatment of waste, handling the residues after the incinera-tion, etc. According to the prescribed regulations, incineration and co-incineration plants have to be de-signed, equipped, built and operated in such a way, that the temperature of the waste gas reaches a temperature of at least 850°C. In the case of incineration of hazardous waste with a content of more than 1% of halogenated organic substances a temperature of at least 1100°C has to be reached. In addition, the incineration plants have to be operated in order to achieve a level of incin-eration such that the residues from the combustion of the total organic carbon content is less than 3% or their loss on ignition is less than 5%. Any heat generated by the incineration or the co-incineration process should be recovered as far as practicable. The emission limit values set out in the Directive’s Annex shall not exceed the threshold values in the exhaust gas. Discharges of wastewater to the aquatic environment resulting from the cleaning of the exhaust gases shall be limited according to the emission threshold values set out in the IED. It should also be noted for the incineration of municipal solid waste that it can only be classified as “recovery”, namely as “R1-operation”, if the incineration complies with the energy efficiency re-quirements as given in the Directive. Serbia tries to support possible investors for the construction of waste incineration plants. So the production of energy from waste is promoted with 7 to 9 cents per kWh. Also the construction of waste incineration plant can be performed with financial aid. But the most difficult point for the op-eration of waste incineration plants in Serbia are the public opinion on waste incineration due to the lack of appropriate information on social, medical and technical implications of waste incineration. This could be made easier by issuing integrated permits (including for cement industry) which cov-er all aspects needed for authorization. This integrated process has not started in Serbia yet. It is necessary to promote the use of BATs and environmentally-sound practice as well as implementa-tion of specially defined emission limit values for IPPC-/IED installations. At present, there are no waste incineration plants in Serbia. However, two cement plants are avail-able for co-incineration of different types of waste with appropriate permissions for thermal treat-ment of waste.

Serbia needs a plant for the incineration of medical i.e. infectious health care waste and for certain hazardous waste types respectively. In accordance with EU regulations, infectious medical waste must be burnt in incinerators designed for that purpose. But the application of autoclaving of infec-tious material in Health Care Institutions, i.e. “in situ” might be permitted for a while.


For hazardous waste thermal treatment is usually realized in rotary kilns and circulating fluidized bed combustion. These plants can treat:

Contaminated solids e.g. soils contaminated with organic solvents

Sludge

Oil/water mixes and emulsions

Chemicals, paints and resins, solvents

Medical and pharmaceutical wastes

Pesticides, PCB, and contaminated packaging waste (e.g. from agrochemicals).

Sometimes such kilns are in use within industrial complexes, in order to destroy their proper pro-duction residues, or for their recovery; in such cases it could be wise to convince such operators to accept certain external wastes for incineration. For certain hazardous waste types, cement plants are often the most suitable solutions. Residues from hazardous waste incinerators usually are hazardous as well; bottom ashes, fly ash-es and residues from flue gas cleaning contain high percentage of heavy metals and soluble salts and therefore need disposal in hazardous waste landfills. The extremely high temperatures in the rotary kilns guarantee complete mineralization of the residues and complete destruction of any hazardous organic compounds. Energy recovery Since several years, fuel production from waste for energy recovery purposes has got a wide-spread and useful technology in many countries. Many waste-to-energy plants have been de-signed, constructed and put into operation since then. Energy recovery from waste with sufficient calorific value helps the industry, the climate and the waste management staff. Many hazardous waste types have a high thermal potential and can be used instead of conventional (fossil) fuels. Cement production is especially favourable of such re-use due to high temperatures and long burn-ing time to ensure a complete destruction of hazardous compounds. Energy recovery from waste in cement kilns achieves a positive impact on the environment, reducing GHG emissions, the use of fossil fuels and the amount of waste that otherwise would end up in landfills. Typical hazardous waste types used for energy recovery in such processes includes used solvents, refinery residues, sludge from industrial wastewater treatment plants, contaminated and halogenated oil residues. The IED (see above) prescribes the tolerated threshold values of emission for the plants using al-ternative fuels. Integrated prevention and pollution control measures define the limits for secondary fuels from waste replacing primary fossil fuels (coal, oil). Cement plants might be an alternative for some specific hazardous waste types; cement kilns are under the scope of the IED and therefore the provisions of the BREF “Cement, Lime and Magnesi-um Oxide Manufacturing Industries (May 2010)” have to be considered. The quality of the waste fuel must be suitable for the industrial furnace. In that context, primarily the following characteristics of the waste fuel have to be considered: Sufficient calorific value in order to substitute use of fossil fuel,

chemical composition must not disrupt the quality of the cement clinker, cement and concrete, and have a negative impact on the health of workers and users,

from their physical properties, sufficient storage stability.

These characteristics can be fulfilled by non-hazardous and hazardous waste types equally. But required characteristics of secondary waste fuels can only be achieved by appropriate sorting, separating, mixing and processing steps in a pre-treatment stage.


Figure 10: Components of a mechanical treatment plant for the preparation of residues (waste) derived fuels

RDF

Incineration technologies The technology of incineration of waste covers the oxidation of flammable materials (i.e. of suffi-cient calorific value) contained in waste. The incineration of waste is applied in view of reducing the waste volume and its inherent environmental and health impact. The energy generated in the pro-cess of burning should be used for obtaining heat or electrical energy for internal and external use. If compared to costs of waste disposal in landfills, the investment and operational costs of incin-erators are higher, (but at the long term environmental and health profits of waste incineration are significant. Problems inherent to waste disposal in landfills can decisively be minimized for a long period of time. In order to achieve a sustainable system of waste management in Serbia, the incineration of waste combined with its energetic use should be developed on a local and regional level. The incineration of waste is essential part of an integrated approach to waste management facilitating reduction, re-use and recycling of waste. In this context, all options of thermal waste treatment should be taken in consideration. New tech-nologies, if reliable and competitive, might also find their place in the sustainable waste manage-ment system. Some of these options are as follows:


Pyrolysis Pyrolysis is the process in which organic waste gets decomposed at high temperatures and in ab-sence of air. During the process, thermal decomposition of organic substances takes place result-ing in pyrolytic gas, oil and solid phase rich in carbon. According to temperature range at which py-rolysis takes place, three types of pyrolysis may be distinguished:

low temperature pyrolysis at temperatures up to 500°C;

medium temperature pyrolysis at temperatures from 500°C to 800°C;

high temperature pyrolysis at temperatures higher than 800°C.

The increase of the reaction temperature results in the increase of the share of pyrolytic gas related to other reaction products, and in the decrease of solid and liquid phase. Pyrolytic gas is usually used for heat recovery, e.g. for heating or generating electricity. The composition of solid and liquid reaction products often has created problems with their adequate disposal. Gasification Gasification is a high temperature process of waste treatment in presence of air or water steam applied to obtain flammable gases. The technology originates from largely applied processes of gas production out of petroleum. One of the products of reaction is a mixed gas. Such gas might be burnt and/or used for energy generation. Due to high temperature of the process, vitrification (smelting to glass) of slags takes place which facilitates their use e.g. in construction purposes. The energy balance risks to be negative due to the high temperature needed.Gasification is still not a widespread procedure for waste treatment since fuel must be relatively homogenous, which is only possible by sophisticated pre-treatment technologies. Plasma process Alternative systems of treatments such as plasma process (energy released by electric charging in inert atmosphere) have been developed. Temperatures between 5,000°C and 15,000°C are achieved in this process. Due to this extremely high temperatures, organic substances are com-pletely decomposed and the resulting mineral residues are melted (vitrified).Intense decomposition of organic molecules takes place in the gas phase, which eliminates toxic compounds completely. Vitrified residues might be used as a construction material or it can be safely disposed of. But plasma processes are extremely expensive and therefore scarcely used.


7.2.1.3 Physical-chemical treatment of hazardous wastes

Physical-chemical treatment (PCT)27 of hazardous waste is a very common and useful technology. The application and combination of such physical and chemical process steps depend largely on the physical and chemical characteristics of the waste. PCT techniques are usually needed for liq-uid waste and mixtures of different liquids and solids; sludge from wastewater treatment in manu-facturing industry is a typical waste for PCT. Typical PCT wastes are: Waste water/ leachate from landfills

Hazardous waste (fluid / pasty)

Sludge from gasoline and oil-water separators and precipitators

Oil-containing liquids / emulsions (service fluids)

Waste oil and oil sludge from metal and electronic manufacturing industry

Waste acids, spent acids

Waste from paints /pigments/solvents

Organic compounds (fluid) from pharmaceutical and chemical industry

Photographic chemicals

Liquid chemical waste from laboratories etc.

Figure 11:Basic components of a physical-chemical treatment plant.

27 As defined in Article 5, paragraph 35 of the WMA is in line with the definition in Directive 2008/98/EC.


PCT techniques include single elements or the entire spectrum of the following process steps: Neutralization (by mixing stoichiometrically waste acids and waste bases)

Flotation (induce chemical reactions for separating solids from liquids)

Precipitation (gravity induced separation of solids and liquids),

Filtration (separation of solids and liquids through meshes),

Stripping (e.g. extrusion of organic compounds from contaminated soils by heat)

scimming (oil – water separation though gravity differences)

oxidation and reduction (chemical reactions in order to diminish the hazardous character of chemical compounds),

adsorption (to fix floating hazardous substances to a solid for precipitating them afterwards) ,

distillation (thermal separation of solvents du to their different boiling point),

ionic changes and reverse osmoses (separation of salts in liquids in order to facilitate other treatment steps),

solidification (by mixing sludges with solidifying ingredients e.g. cement or chalk), and

other physical and chemical processes by which toxic features of waste are reduced.

Figure 12:Components of a physical-chemical treatment of inorganic hazardous waste streams.

In many countries solidification techniques are the final process step before landfilling in order to improve the chemical (solubility) and mechanical (stability) properties of the waste to be landfilled. Solidification techniques are only helpful for the treatment of mineral sludge containing heavy met-als and other inorganic hazardous compounds.


Figure 13: Components of a physical-chemical treatment of organic hazardous waste streams

7.2.1.4 Recycling, reuse and prevention of hazardous waste

Material recycling of hazardous waste

Recycling of hazardous waste is as important as recycling of municipal waste, since in both cases significant technical, environmental and economic effects are obtained. The most important effects are: significant reduction of waste quantities to be disposed of in incineration plants and in landfills,

and so far prolongation of the time life of landfills, and

significant diminution of use of (fossil) natural resources and

significant reduction of emissions from waste disposal activities.

This is true also for end of life products, which might be hazardous (e.g. ELV or WEEE) as well.

Typical steps to material recovery of waste, hazardous and non-hazardous are as follows: Separation of different waste streams at the source of waste generation; this might take place

within the household or by collection of certain end-of-life products by aretail, or by separate container collection in recycling centers.

Further mechanical separation (e.g. dismantling) of recyclable material components out of the different waste streams in treatment facilities; this ranges from pure labour work up to highly sophisticated automatic processes to separate different material streams.

Extraction of recyclable materials in the quality of secondary raw materials with an economic value for the manufacturing industry with additional process steps like compounding of plastics, spilling of cartboard, grinding of glass and pressing of metals for suitable packaging and for preparing transportable units.


Examples for such complex treatment and recycling measures are the re-raffination of waste oils, the dismantling of WEEE and ELV or the distillation and re-use of solvents. Reuse and prevention The prevention of waste from products begins with the design of new products as first step of the decision-making process in production technology and as first step in the life cycle of a new prod-uct. Waste prevention so far is part of manufacturing, packaging, transporting and placing products on the market and not part of the waste management activities in a narrow sense. But waste man-agement decisions (e.g. landfill taxes, threshold values) can influence the behavior of production engineers and also consumers can take an active role in the reduction of waste by purchasing products with less packaging material and other advantages like repair friendly construction and long life promises. The government as a whole should take responsibility for its waste reduction policy. Meanwhile, certain products have been designed for multiple use. Provisions on packaging materi-al in EU Regulations encouraged manufacturers to apply packaging material for multiple use. Reasons for waste reduction and products re-use are: cost reduction both for manufacturers and consumers;

savings in energy and raw materials;

reduction of waste disposal costs.

7.2.2 Options for the treatment, recovery and disposal of hazardous waste from industry and commerce

In Serbia the treatment of hazardous waste from industry and commerce will entirely be realized by the private waste management sector under the stringent regulatory framework of hazardous waste legislation. The sector of hazardous waste treatment will develop step by step with the increasing demand of waste generators, the increasing costs for treatment abroad and with the increasing skills of Serbian treatment facility operators.

Industry itself might play an important role in this context; manufacturers have the necessary tech-nological know how to handle their own residues and might have an increased economic interest to hold their waste in their proper hands till recycling is completed. Several industrial complexes might have their own thermal centres for energy supply and their own landfills. It could be economically feasible for them to improve the state-of-the art in these installations and increase their capacity in order to offer their treatment and disposal services to the market.

Expected quantities of industrial waste from manufacturing industry and other sectors have been calculated in this HWMP (see also chapter 6) as follows: Estimated amount of chemical wastes and industrial effluent sludges generated, and potentially separately collected in the near future in Ser-bia, is approximately 39.000 tonnes/year.. This waste predominantly needs physical-chemical treatment.

When new waste treatment capacities will be installed, more secondary hazardous wastes will be generated. The future quantity of residues from waste treatment (EWC group 19 02) to be disposed of in 2020 will arise to 7.000-10.000 tons per year. This waste predominately will be landfilled.


For hazardous waste from sorting facilities (e.g. batteries) and mineral wastes from waste treat-ment and stabilisation facilities a generation rate of 1 kg per capita was assumed based on the da-ta from other countries. The estimated total quantity of these secondary hazardous wastes would be 7.000 t. This waste predominately needs landfilling. For the estimation of the future quantities of hazardous combustion wastes (EWC group 10.02) it is assumed that the quantity of hazardous combustion wastes would amount to 12.400 tons in 2020. This waste predominately will also need landfilling. 7.2.3 Options for the treatment, recovery and disposal of hazardous waste from

the construction sector

Hazardous construction waste must not be disposed in the sites where such waste has been gen-erated, nor can it be disposed in locations not particularly stipulated for such purposes. This means that owners of the hazardous construction waste shall be obliged to ask for assistance of special-ized enterprises to provide separate collection and temporary storing of this waste and has to bear the costs for this waste management. This sector will develop step by step with increasing re-quirements of competent authorities to separate and collect these wastes in an appropriate way. In the draft Serbian Waste Management Plan for Hazardous Construction and Demolition Waste forecasts have been made for the quantities of hazardous construction and demolition waste gen-erated in 2020 in Serbia. It is assummed that about 4.000 t of hazardous construction and demoli-tion waste, mainly soils, wood and asbestos cement, need to be treated in 2020. According to the estimations in this HWMP (see chapter 6), it is expected that up to 40.000 t /a of asbestos wastes (mainly asbestos cement) will be generated in the future. However, the amounts of future yearly generated and reported C&D waste containing asbestos strongly depend on the es-tablishment of a proper waste management scheme. Thus the quantities of asbestos containing waste might be much lower. The treatment of hazardous C&D waste needs to be established in Serbia. Capacities for the treatment of separated hazardous wastes from C&D waste need to be sufficient with adequate ge-ographical spread at the territory of Serbia. Asbestos-containing waste is the most frequent and problematic category of hazardous construc-tion waste. Taking into account the ban on asbestos containing products and according to the Ser-bian Law on Waste Management (Article 54) asbestos containing waste shall be deposited at land-fills on a visibly marked area intended for disposal of asbestos-containing waste. Asbestos-containing material shall be taken out of the life cycle as early as possible (at the next opportunity which does not entail excessive costs) and must not be reused.Asbestos-containing waste shall be prepared for transportation and disposal by applying specific treatment techniques. Besides chemical treatment with hydrofluoric acid and thermal treatment (incineration in rotating kilns with at least 1100 o C, melting with at least 1400 o C, plasma melting), the disposal on landfills in separate areas with daily covering is an adequate and cost effective solution for many asbestos waste. Asbestos cement can directly be landfilled under specific precautionary measures. Asbestos fibres from clean up procedures are to be solidified at place of generation and then landfilled. Asbestos contaminated equipment (e.g. protective clothing, etc.) is treated with organic binder to bind resid-ual fibres. Asbestos-containing waste is typically packaged and disposed of at marked areas on registered landfill sites. In case that the landfill is licensed to dispose asbestos containing waste the personnel responsible for input control and on-site verification need to be trained on the related issues. The minimum requirements for the trained personal can also be achieved via their educational back-ground.


Asbestos cement does not cause any emission after landfilling, however during the process of demolition of a building and in the whole transport chain to a landfill site as well as during the dumping of the wastes there is a high risk of fibers emissions. Within the landfill, the asbestos deposit zone is to be covered daily and before each compacting with appropriate material; non-packed waste is to be sprinkled regularly. If the asbestos cell of the landfill is filled it is to be finally covered. No work is allowed which may cause a release of asbestos fibers (e.g., no drilling of holes). Following the closure of the landfill a site plan has to be kept show-ing the location, type and amount of asbestos waste landfilled. Following the closure of the landfill appropriate measures are to be taken to prevent possible alternative uses of the land so that no human contact with the waste is possible. These requirements shall be part of the close down plan of the landfill. The Serbian Regulation on Disposal of Wastes on Landfills already provides the necessary legal framework for this co-disposal of asbestos wastes in line with the EU Landfill Directive. Co-disposal of asbestos wastes needs a specific authorisation (license) in accordance with the Regulation on Disposal of Wastes on Landfills. Such a license shall contain a description of the specific proce-dures to be followed in the onsite inspection of asbestos wastes. The recent capacities for co-disposal of asbestos-containing waste at the three sanitary landfills in operation account to more than 20.000 tonnes. At least one company has a permit for physical-chemical treatment of asbestos waste. In specific cases asbestos containing equipment may be recycled, provided that the asbestos con-tent is totally removed and disposed of save and environmentally sound. An example for such a waste stream is e.g. asbestos containing gas cylinders. This material cannot be landfilled because of the content of organic solvents and has to be dismantled. This process can be assigned as re-covery operation R4 while asbestos is recovered as a residue destined for final disposal after ap-propriate pre-treatment. The necessity of a more sustainable waste management system in C&D waste management will accelerate the demand of adequate asbestos waste management techniques because asbestos cement and weak bound asbestos hinder the success of C&D waste recycling. On a short term, the disposal of contaminated soils and C&D waste in controlled and well equipped landfills is of great importance in order to further reduce discharge of PCBs from poorly sealed dumps. Giving the average life span of a building, the problem of POPs-containing demolition waste may be of lower priority on a long term. It is not possible to derive a forecast on the future amounts of contaminated soils. Annual amounts on the generated contaminated soil may vary widely since this waste arises only at contaminated sites and the generated amount is related to single site clean-up. Depending on the quality of the soil it can be either co-disposed at sanitary landfills in Serbia or chemical-physically/biologically pre-treated for further disposal or recycling.


7.2.4 Options for the treatment, recovery and disposal of hazardous waste from the medical sector

Infectious Waste Expected quantities of infectious waste have been calculated in this HWMP (see also chapter 6) as follows: For planning purposes a generated quantity of 5,000 tons per year is assumed. Although a sound and country-wide basis for infectious waste treatment is in place, the system is not yet fully developed and is functioning with varying levels of success. In theory the current in-stalled capacity is sufficient to treat all the generated infectious waste. However, various operation-al and financial problems prevent the system for be fully utilized. The management of pharmaceutical waste is fragmented. Without treatment capacity in place in Serbia and without arrangements for the funding of collection, transport and export for destruction abroad, the few pharmaceutical institutions that do accept pharmaceutical waste from households, store the waste in a variety of places and circumstances. In some healthcare institutions pharma-ceutical waste has accumulated over a period of 40 years or more. A system for the management of chemical waste from the healthcare sector is not yet in place. Chemical waste is managed by individual healthcare facilities whereby discharge into the sewer system is the most frequently used method. Some hazardous chemical waste is stored indefinitely, while treatment and export for incineration abroad is taking place on an occasional basis. Treat-ment and export is conducted by private companies which possess the environmental permits to do so. Healthcare waste management is a chain of interlinked actions and processes for each of which different technical options exist. Choices made for one action or process influence choices to be made for other actions and processes. A choice for disposal of infectious waste by landfilling im-plies that pre-treatment of infectious waste, for instance by steam sterilization, will be required while a choice for incineration could replace a sterilization step. The healthcare waste manage-ment chain comprises the following elements. The National Plan for the Management of Healthcare Waste presents the policy goals of the Gov-ernment and the policy measures the Government will take to realize these goals. The elaboration of this national Plan is prescribed by Law. The following technical options are feasible for the healthcare waste treatment and healthcare waste disposal: (Steam) sterilization followed by landfilling

Incineration

Physical-chemical treatment

Not all of the above mentioned technical options are equally suitable for all types of waste: The de-cision for sterilization of infectious waste implies that another solution for pharmaceutical and chemical waste will be required e.g. physical-chemical treatment; this could be avoided by inciner-ating all of them. In Serbia, government decided for current district based CTPs and LTPs establishing the basis for the treatment of infectious waste; this implies that additional facilities for the treatment of non-infectious waste shall be needed. In the short-term the existing autoclaves shall continue to be in operation. The equipment shall stay in use during the respective length of their life. In practice this means that the existing autoclaves will provide the necessary treatment capacity for infectious waste till the year 2020.


For the treatment of pharmaceutical and organic chemical waste from HCWM, a containerized small-scale incinerator (SSI) facility including storage area is to be established in the Belgrade ar-ea. The SSI will not provide a solution for inorganic chemical waste from medical laboratories. The incinerator must be in full compliance with the legislation for the incineration and co-incineration of waste. To achieve such compliance, the capacity of such incinerator should exceed the needs of the HCWM sector, giving the opportunity for treatment of hazardous waste from other industrial and commercial sectors as well. As funding and location are not yet determined, export of pharmaceutical waste, notably expired cytotoxic and cytostatic material, will continue for a couple of years for high temperature (1100 oC) incineration. The above leads to the following short term healthcare waste treatment and disposal policy:

Optimal utilization of donated steam sterilization equipment

Export of pharmaceutical and hazardous organic chemical waste for incineration abroad till the realization of incineration capacity in Serbia

Realization of a small scale incinerator for the incineration of pharmaceutical and hazardous organic chemical waste

Treatment of hazardous non-organic chemical waste in existing installations in Serbia or storage till such capacity is realized.

In the longer term, from 2021 onwards, new treatment technology will have to be put in place and the Government’s policy aims at the realization of a spectrum of technologies which take into ac-count the existing situation in Serbia including the need for an integrated solution for all HCW. A combination of different technologies will be implemented. According to the legally binding landfill regulation, infectious wastes and body parts and organs are not allowed to be landfilled. The guide-line requires the thermal treatment without any previous treatment or partly recycling of such wastes. It is not allowed to incinerate such waste in co-incineration facilities e.g. cement kilns etc. Needed capacities have been calculated by the EU funded HCW project based on data collected by the project partners. The forecast is included in National Waste management Strategy (NWMS). This slightly contrasts with the NWMS which calls for one central hazardous waste incinerator and treatment facility for HCW in Serbia. Since the adoption of the NWMS there have been new devel-opments, e.g. with regard to the availability of preferable sites of the plant or concerning hazardous waste amount requiring incineration; this is why certain adjustments to the approach anticipated in the NWMS are required. One important reason for adjustments relates to the required collection frequency for infectious waste which is 1 to 5 days. This limits the feasibility of centralized treat-ment of infectious waste. For infectious waste a decentralized approach has been adopted there-fore: Autoclaves will stay for a much longer time the choice for infectious HCW in Serbia. The above leads to the following long term HCW treatment and disposal policy: Realization of a waste-to-energy plant near the City of Belgrade and co-incineration of all

healthcare waste generated in Belgrade in such plant with the exception of cytotoxic and cyto-static waste, inorganic chemical waste and hazardous organic chemical waste.

Treatment of infectious waste generated in Vojvodina in a large autoclave with internal shred-der located in one central infectious waste treatment facility

Treatment of infectious waste generated in central Serbia in eight medium sized autoclaves with internal shredder located at the regional waste management centers to be established

Incineration/treatment of cytotoxic and cytostatic waste, inorganic chemical waste and hazard-ous chemical waste from Belgrade as well as all pharmaceutical, cytotoxic, cytostatic waste and chemical waste from Vojvodina and central Serbia in a central hazardous waste treat-ment facility.


In consequence, export of pharmaceutical and chemical waste will stay an integrated part of the HCWM system till the completion of treatment capacity in Serbia. Thus, the export will be limited to pharmaceutical and hazardous organic chemical wastes, if Serbian Industry doesn’t initiate its proper solution for thermal treatment of chemical residues. 7.2.5 Options for the treatment, recovery and disposal of hazardous waste from

households

The treatment of hazardous waste collected from households (HHW) is integrated part of the treatment techniques applied and installed for commercial and industrial residues, because these wastes reflects the whole scale of produced substances and consumer goods in use in Serbia. Hazardous waste from households consists of paints, solvents, household cleaner or care products as well as end-of-life –products like batteries, lamps and electronic devices. Based on the statistics of selected other countries, it is assumed that between 4.000 and 8.000 t of hazardous wastes from housholds will be separately collected in Serbia in the future. After separate collection and storage, the flow of hazardous waste from households is going to be integrated in the general flow of hazardous waste streams and their appropriate treatment. 7.2.6 Options for the treatment, recovery and disposal of hazardous

agrochemicals’ and industrial packaging waste

In principle, the private sector is responsible for the packaging placed on the market. This is espe-cially true for the collection, recovery and recycling of industrial packaging waste. This type of hazardous packaging waste is generated by: Industrial processes. The largest quantities come from five sectors: chemical and pharmaceuti-

cal manufacture, metals refining, petroleum and coal products, metal working and fabrication, rubber and plastics manufacture. It is up to them to find out the best methods to recover and recycle their waste.

Agriculture processes: In this case, the crop protection industry (agrochemicals industry) has to take the responsibility to such waste.

However, the Serbian industry is faced with the lack of treatment facilities within the country and thus the hazardous packaging has to be exported for treatment, which is at a higher cost. Thus, producers are using intermediate storage facilities followed by export. This is also the case for pri-mary packaging waste from the agrochemicals industry. At present, the crop protection industry is carrying out a market assessment in order to identify the most efficient and cost effective way of achieving the responsibilities. Most common recipients are steel drums and plastic containers of different size and material. The management system of such containers should be designed in such a way to ensure that, in case the collected recipients shall undergo a recycling operation, the resulting products (sound recipi-ents or resulting secondary raw material) are intended for a use that by no means pose any hazard (e.g. the plastic products made from such secondary raw material should not be used for food packaging). Even if recycling and re-use of recycled plastic might be more cost-effective than in-cineration, the crop protection industry prefers such measures. Thus, after collection, the plastic waste containers should undergo the following treatment steps: Recycling: Converting plastics waste into useful new plastic items is feasable, where the collect-

ed material is clean and the material does not contain different polymers/laminates;

Thermal treatment, through incineration, if recycling is not feasible;


Co-incineration in clinker production process in cement kilns (carrying out incineration), if opera-tors are willing to accept such waste and emissions correspond to legally prescribed threshold values. If dedicated Waste-to-Energy facilities are not available, cement kilns could be suitable for energy recovery of agro-chemical packaging waste. In such case, the Serbian Cement fac-tories should continue investments in order to fulfill the requirements for energetic use of such hazardous waste.

Alternatively, the plastic waste from hazardous packaging can also be used as alternative fuel in a steel blast furnace to reduce iron ore. This process can also accept mixed plastics as the temperature of the furnace is sufficiently high to destroy residual pesticide contaminations.

The proposed steps of such a system for agro-chemicals packaging are: Triple rinsing of primary plastic waste containers within a coherent scheme under the central en-

vironmental authority supervision, followed by

Recycling only in facilities which can ensure the traceability of final products or

Co-incineration in cement kilns.

The latter mentioned option is pendant that the cement industry obtains the environmental permit to treat such type of waste. Currently, cement factories in Serbia don’t have permits for thermal treatment of this type of waste, however, the EU experience has shown that with adequate, strictly controlled pre-treatment, this kind of hazardous waste can be thermally treated in cement kilns. Investments of cement industry in Serbia in providing conditions for treatment of hazardous agrochemical and industrial packaging waste will greatly depend on the projection of separate collection of this type of waste in Serbia in the future and providing mechanisms for separate collection of such waste (i.e. special collection schemes). Co-incineration in cement kilns will largely depend on the availability of adequate implementation of pre-treatment, while the availability of the cement industry in Serbia and permits for thermal treat-ment of such prepared agrochemical packaging is already provided. For POPs packaging containers mainly made of metals, plastics and metal/cardboard have been used; in some cases the composition of this packaging is not clearly known. Some companies en-visage washing of packaging containing POPs for the purpose of subsequent incineration of the washed empty packaging in cement kilns. The input of POP-packaging into cement kilns in Serbia could be envisaged, depending on the technology used by the cement industry. It is recommended to assess the facility’s permits in detail with regard to the possible incineration of POPs-wastes. Technical expertise shall be required referring to the possible input of POP-wastes, monitoring and evaluation of the emissions within a trial incineration should be required. As shredding of POPs containing packaging may be necessary prior to the input into the cement kiln, emissions of ex-haust air resulting from the shredder process must be captured and purified (e.g. feeding them to the cement plant). With reference to the pesticides POPs the cleaning/re-use of washed plastic container as well as the material recycling of this plastic cannot be recommended. Most of the POPs are highly soluble in hydrocarbons and migrate into plastics especially PP and PE. The washing results in contami-nated water or solvents which again need a specific treatment as POPs waste. Washing/rinsing of POPs-packaging waste shall be prohibited in Serbia due to the lack of adequate waste water purifi-cation standards and the fact that this method does not destroy POPs. Therefore thermal treatment of POP-packaging in adequate facilities (export to hazardous waste incineration facilities) is neces-sary. No quantities and no prognostic amounts for hazardous packaging are available at present.


7.2.7 Options for the treatment, recovery and disposal of waste oils

Approximately 25,000 tons of waste oil are expected to be provided to the official waste treatment sector in the future. Furthermore, with implementation of increasing environmental standards in Serbia, e.g. by widely used oil/water separators at petrol stations, garages etc. relevant additional amounts of oil containing wastes from these installations will be generated. Provided that the Serbian cement plants, which currently do not have a permit for the co-incineration of waste oils, will apply for a permit to co-incinerate waste oil in future, no further ca-pacities for the final treatment (recycling and incineration) of generated waste oils are required in Serbia. All three cement plants are ready to expand its capacity for thermal treatment of waste oils to the extent that total amount of waste oil generated in Serbia could be treated in this way. For certain quantities of halogenated waste oils (incl. PCB) and waste oils with a relevant content of other hazardous wastes (e.g. due to specific chemical formulation or accidental or intentional mixing) exporting for treatment in appropriate facilities may still be required in the future. Several types of oil wastes have to undergo specific pre-treatment before they can be used as an input in re-refining or energy recovery (as fuel) processes. Figure below gives an overview on treatment options for oil wastes. Technical details are provided in the Manual on “Technical as-pects of waste oil management”, which is supplemented to the Serbian Waste Management Plan (SWMP) for Oil Wastes. There are several steps of treatment necessary for oil recycling: Mechanical separation: It can be used for the treatment of solid containing liquids (oils) and for

the treatment of complex wastes (e.g. blended materials such as used oil filters). The mechani-cal separation techniques like sieving, filtration, centrifugation etc. are usually only the first step in the treatment chain and the recovered liquid phase may be subject to further treatment.

Chemical separation of different components of oil emulsions: Emulsions are mixtures of two or more normally immiscible liquids. One liquid (the dispersed phase) is dispersed in the other (the continuous phase). Stable emulsions may form when machines clean vehicles and/or ap-ply emulsifying surfactants. Furthermore, particular lubricants such as machining oil are already applied as emulsions stabilised by emulsifiers. In order to split these stable emulsions the ef-fect of the tensides or the emulsifiers must be neutralised. If the two liquids have different den-sity then a phase separation will occur by gravity separation. The floating oil phase can then be removed by a skimmer. This separation can be enhanced again by applying centrifugal force.

Final treatment of the oil fraction: There are two options for the final treatment of waste oils and other oil containing wastes: re-refining (recycling) and recovery for further energy supply.


Figure 14: Overview of the main treatment steps for waste oil (from SWMP)

In general, there is a market demand for waste oil for energy production (as fuel), since for energetic use no high investment costs are necessary. Investment costs for secondary oil re-refining are sub-stantially higher. However, taking into account the whole chain of production of new mineral oil prod-ucts and fuels, in several cases, recycling has been identified as the preferred option. The aim of waste oil refining is to produce a secondary material of the same quality as virgin material. Industrial waste oil recycling normally combines several recycling steps in order to produce a high grade sec-ondary product. Many oil containing wastes (oil-water mixtures, separator contents (sludge), oil recovered from emul-sions), however, have a varying composition and may not always be fit for recycling. Such wastes should preferably be recovered and converted into secondary fuel serving the demand of industrial co-incineration plants. Such oil containing wastes not suitable for recycling can be used either as liquid secondary fuel or as a solid secondary fuel. Several oil containing wastes and residues from pre-treatments have to be disposed of. But oil con-taining sludge is not fit for landfilling. Thus stabilisation methods which are capable to solidify even a material with high concentrations of hydrocarbon have been developed, but not applied in a sensitive scale. Such treatment technologies waste energy and are consuming resource; they may thus de-crease the environmental benefit from using the energy content of the waste. It may be preferable to produce a solid secondary fuel by conditioning oil containing sludge, provided that this waste then meets the quality criteria for co-incineration. To handle secondary fuel in the incineration plant a pourable material is preferable. In general two physical treatment options are available: The most common way to make oil containing sludge pourable is mixing/blending with combus-

tible absorbing material, such as wood shavings, de-gassed PU-foam or textile fibres (= physi-cal conditioning/stabilisation), all coming from the waste management sector.

Biological treatment was also used successfully to produce a pourable RDF from oily sludge, e.g. from P/C-treatment.


Wherever threshold values for legally prescribed pollutants cannot be met from oil containing wastes, (including oil contaminated soils), these wastes have to be incinerated in specialised combustion plants. Soils with low levels of contamination may be disposed of in landfills, either directly or after e.g. biological pre-treatment, provided they comply with landfill criteria. Waste prevention for waste oils can be achieved by more rational use of better quality oils, introduc-tion of modern technologies with less demand and less consumption of oils. Indicator for such devel-opment could be the ration between oil consumption and car fleet in Serbia.

7.2.8 Options for the treatment, recovery and disposal of hazardous waste

streams covered by extended producer responsibility systems

7.2.8.1 Treatment of waste batteries and accumulator,

The classification of batteries according to battery chemistries, which is presented in the table in Chapter 7.1.7.1 is useful to give information on specific treatment requirements This classification is useful to give information on specific storage requirements. Treatment re-quirements with regard to the battery chemistry are as follows: Lead acid batteries A recovery process for lead acid batteries and accumulators in compliance with best available techniques should at least compromise the following steps: Separation of solids and acid; the acid should be recovered

Separation of plastics (polypropylene PP, ebonite, PVC) for further separate treatment.. The plastic should preferable be used for the production of new battery casings.

Conversion of lead sulphate to lead oxide or lead carbonate in a thermal process.

Conversion to lead carbonate and the use of carbonate as a flux has the advantage of reducing the melting point of the slag and thus of reducing the energy consumption. However, the result-ing so called soda slag is easily leachable and requires a specially engineered landfill for safe disposal.

Best available flue techniques for the lead smelter process comprise an afterburning chamber or an oxygen burner. The crude lead produced may need further refining to separate alloying metals. In specific cases the recycling plant may perform only the separation step while the lead recovery is done at a dedicated smelter somewhere else. According to the estimations carried out for this HWMP (see Chapter 6), about 18,000 t of lead-acid accumulators are expected to be generated in Serbia in the future. Capacities for the recycling of lead-acid accumulators already exist in Serbia and no further capaci-ties for the treatment of lead-acid accumulators are required. Lithium batteries Since Li-batteries are liable to catch fire when the sealing is damaged the first treatment/recycling step (after sorting/separation) is the crushing of the Lithium batteries and the mechanical separa-tion of the components in an inert atmosphere. Although Li-batteries and especially Li-accumulators contain organic solvents (up to 10%) the elec-trolyte in most cases cannot be recovered for reuse. Typically the electrolyte is absorbed by a powdery fraction formed by Mn-oxides, Co-oxides and other transition metals.


In most cases a higher efficiency can be achieved when there is a separation into specific material streams which can be recovered in different highly specialised smelters. However, the licensing process for exports is more complex in such cases. Most of the secondary lithium batteries do not contain metallic Lithium but an intercalation com-pound of Lithium with either graphite or a transition metal oxide. These intercalation compounds are less reactive than metallic Lithium. Nickel batteries Recycling normally starts with a dismantling step, separating the battery into cathode, anode, sepa-rator, casing and electrolyte. The Ni-anodes as well as Fe-cathodes have been used directly in iron and steel production (especially in electric arc furnaces). The casing may consist of high grade plastics (PP, PE) or iron/steel while the separator may be a plastic or glass fleece. The standard process today comprises the combined treatment of sealed NiCd-batteries and in-dustrial Nickel batteries in a mechanical process, followed by a thermal process. The thermal pro-cess recovers metallic cadmium and an iron/nickel mixture ready for additional metallurgical pro-cesses (e.g. production of ferro-nickel in an electric arc furnace). Nickel-metal hydride batteries need a specific pre-treatment to avoid explosive hydrogen containing atmospheres during battery dismantling. Relevant emissions may occur to air as well as to waste water and thus must be abat-ed. NiMH batteries consist of a NiOOH cathode, a caustic electrolyte and an anode consisting of an al-loy capable to form metal hydrides. In (partly) charged condition the anode alloy contains a metal hydride which may decompose to hydrogen and the pure alloy if the sealing of the cell is damaged. NiMH batteries therefore pose a higher risk of self-indignation than other secondary batteries. Es-pecially in the recycling process when the sealing of all batteries is broken specific care has to be taken to avoid oxyhydrogen gas explosion. Thus NiMH batteries shall be sorted and recycled sepa-rately. Zinc based batteries Zinc containing batteries shall be separated from other battery types by means of sorting in order to allow an efficient recycling of the Zinc fraction. The most common zinc based battery systems are AlMn and ZnC cells used as consumer batteries. AlMn and ZnC batteries contain complex mixtures of iron/steel, a small amount of non-ferrous metals (brass), Zn-compounds, Mn-compounds and electrolyte. They are recovered mainly in thermal metallurgical processes. Waste Battery Recycling Processes Eight “state of the art” waste battery processes from European companies are listed below: 1. Mechanical separation or thermal treatment separation and subsequent and subsequent

Waelz process for (primary) ZnC and AlMn batteries 2. Pyrolysis and pyrometallurgical treatment for ZnC, AlMn and ZnAir batteries (primary) or ther-

mal treatment of button cells and hydrometallurgical treatment of ZnC and Alkaline batteries (primary)

3. Pyrometallurgical treatment for ZnC and AlMn batteries and NiMH accumulators (primary and secondary) or Oxyreducer: Thermal process under reductive atmosphere for ZnC, AlMn and lithium batteries (primary)

4. Cd-distillation for NiCd batteries (secondary) 5. Mechanical separation for NiMH accumulators (secondary) 6. Pyro- and hydrometallurgical treatment for sorted Li-ion and NiMH batteries (secondary) or py-

rometallurgical treatment for Li-ion and NiMH batteries (secondary) only 7. Room temperature treatment process for AlMn, ZnC, ZnAir and Li-ion batteries (primary and

secondary) 8. Pyrometallurgical treatment for lead-acid batteries (secondary).


Up to now no regular separate collection of waste portable batteries and accumulators takes place in Serbia and there are no reliable data on amounts of portable batteries and accumulators gener-ated. The exported amounts of portable batteries and accumulators are also low (. Used batteries usually end up in municipal waste landfills. Several operators of WEEE treatment plants have already expressed their interest in the collection and treatment of portable batteries and accumulators. The operators currently separate batteries and accumulators derived from dismantling of WEEE. Operators of WEEE treatment plants are interested to run a sorting of portable batteries and accu-mulators and to deliver the different technologies of batteries and accumulators for further and/or final treatment. Missing appropriate technologies in Serbia, this further/final treatment will have to be done abroad. With regard to the low amounts of waste portable batteries expected to be collected in the coming years (350 – 620 t), the installation of special treatment plants for particular portable battery types in Serbia does not seem economically feasible. However, a sorting facility might be feasible in the medium-term. Landfilling of used batteries and accumulators should be prohibited, as well as their burning. The recycling efficiency targets should be monitored as well. The recycling efficiencies should be: 100% for lead acid batteries,

75 % for Ni-Cd batteries and

50 % for other batteries.

7.2.8.2 Treatment of WEEE

Basic legal requirements regarding management of WEEE are given in Article 50 of the Waste Management Act (WMA) (Official Herald RS No 36/09). Detailed provisions were laid down in 2010 in the Ministerial Order on the list of electric and electronic products, measures of prohibition and restriction of use of electric and electronic equipment containing hazardous substances, methods and procedures of managing waste from electric and electronic products (Official Herald RS No. 99/2010). The Serbian WMA among other principles stipulates in Article 6 the principles of “producer respon-sibility” and the “polluter pays” principle. The first requires that producers, importers, distributors and retailers of products that affect the increase in the amount of waste are responsible for waste resulting from their activities. The producer shall bear the greatest responsibility as he determines the composition and characteristics of products and their packaging. The producer shall be obliged to ensure the reduction of waste generation, production of recyclable products, as well as the de-velopment of reuse and recycling market. The latter obliges the polluter to bear the full costs of his actions. The cost of production, treatment and disposal of waste must be included in the product price. However, there is a lack of some essential provisions necessary for establishing a functioning WEEE management system in Serbia. Detailed rules how producers/importers have to comply with their obligations or delegate all their obligations are missing till now. While the Ministerial Order on WEEE gives the collection targets, it does not state who is responsible for achieving these targets. According to the estimations carried out for this HWMP (see Chapter 6), between 20.700 and 27.600 t of WEEE are expected to be separately collected in Serbia in the future.


In 2012 twelve Serbian companies had a permit for the treatment of non-hazardous WEEE; 8 fur-ther companies had a permit for treatment of non-hazardous and hazardous WEEE. For four facili-ties more detailed information was available. The treatment capacity of these plants amounted to nearly 65,900 tons per year. No additional treatment capacities are therefore required for the first treatment step of WEEE. For manual dismantling activities usually there is no limitation regarding the plant capacity. For the treatment of some components derived from WEEE-treatment, which are now exported, stored or disposed, the need of recycling facilities has to be balanced individually taking into account the costs for / revenues from exporting them and the potential waste amounts.

Figure 15:Components of mechanical treatment of different types of WEEE.

Metal fractions derived from treatment of WEEE are traded by numerous scrap metal traders in Serbia. Indication is given that several of them are operating without a license and may also export wastes in a legally non-compliant way. Serbia has a steel work, Cu and Al-smelters. Electronic components containing precious metals, such as printed circuit boards, are partly exported. Several installations for the mechanical treat-ment of cables, for recovery of Cu and other metals are available. For some pure plastic fractions recycling facilities are available in Serbia. Selected waste plastics (e.g. housings) are exported. Hazardous components, such as batteries, capacitors, CRT-glass or fluorescent dust are currently stored. Residual fractions are disposed of at landfills. As residual fractions with a certain calorific value (plastics) usually do not comply with requirements for RDF for co-incineration plants, as soon as also landfilling is no legal option any more, capacity for waste incineration will be needed. However, such waste streams are considered of minor rele-vance compared to other wastes requiring waste incineration capacity. Environmental sound treatment of WEEE aims at the removal and appropriate treatment of com-ponents containing hazardous substances, in achieving high material recovery rates and in reduc-ing the amounts of WEEE and parts thereof being disposed at landfills.


The treatment steps are different for different categories of WEEE. Large (household) appliances In general there are 2 treatment options for large appliances: De-pollution by manual dismantling with removal of PCB-containing capacitors from older wash-

ing machines, Hg-switches from boilers or waste oil from heaters) only and mechanical condi-tioning of the remainder in a shredder, or

Complete manual dismantling with de-pollution and separation into various recyclable fractions.

Cooling and freezing appliances It is necessary that a separate recovery of refrigerants should be established. Also, the remaining gas from electrical devices using gas must be collected. Minimum standard for treatment of cooling and freezing equipment are: Step 1: Acceptance Area: At the acceptance area, appliances are weighed, visually checked and

preliminary sorted into different types of cooling appliances (CFC, hydrocarbon and appliances with NH3).

Step 2: Manual Separation and Sorting: Recyclable parts and hazardous parts are manually separated and sorted (drawers made of metal, glass or plastic, door seals, cable with plug, lamps and condensers).

Step 3: Separation of coolant fluids: The coolant fluids are sucked off after cutting the pipe. Compressor oil and coolant agent (CFC, FC, hydrocarbons) are separated. As an average, old refrigerators may contain 0.15 to 0.2 kg CFC (R12) in the cooling circuit and another 0.3 kg in the insulation.

Step 4: Separation of the compressor

Step 5: Shredding and material sorting: The remaining body will then be shredded to release CFC from the insulation foam. Shredding is performed in a closed compartment which is kept under negative pressure in order to prevent release of CFCs to the environment. After shred-ding, the material is sorted (magnetic separation, eddy current separation and air stream sort-ing, etc.), which results in ferrous metal, non-ferrous metal, plastics and foam.

Step 6: Stripping CFC from the PU foam: CFCs are stripped and liquefied (approximately 0.5 kg per appliance. Treatment installations for cooling and freezing equipment are technically so-phisticated and require substantial financial investment. A minimum throughput of at least 10,000 tons per year turned out to be necessary for operating such an installation in an eco-nomically feasible way.

Display screen equipment Two display screen types are to be distinguished in treatment technology, Cathode ray tubes and flat screens: Cathode Ray Tube (CRT)-Appliances There are 2 technical options for the treatment of CRT-appliances: 1. Manual dismantling of the housings and removal of CRT

a. The housings are removed, cables are cut off. In the case of monitors Aluminum plates are removed. Printed circuit boards are removed and de-polluted (batteries and capacitors are removed). The tube has to be vented in order to prevent implosion. This can be accom-plished either by breaking the panel glass at its thinnest or by removing the base of the tube using a hammer. The electron source is removed from the tube and the getter has to be removed from the electron source. Finally the CRT is separated from the front housing.

b. The removed cathode ray tube has to be further treated. It aims in separating the 2 differ-ent glass types (Pb-containing, Sr/Ba-containing) and removal of the fluorescent coatings. Splitting of the CRTs is performed either by using automatic splitting units based on “hot-


wire-cutting”, thermal shock, laser cutting, diamond saw, laser saw etc. or by manual sepa-ration.

2. Treatment of Cathode Ray Tubes (CRTs) 3. Mechanical treatment of un-dismantled CRT-appliances

a. Un-dismantled CRT-appliances can be shredded in encapsuled shredders with exhaust air treatment. Subsequently the glass is separated mechanically from the other materials (plastics, circuit boards and cables). Different types of glass can be separated using differ-ent techniques like density separation, sizing, UV light, visible light or X-ray fluorescence.

Flat Screen Appliances With regard to the fact that flat screens are just beginning to become waste, research and devel-opment of treatment options is still ongoing. Currently 4 treatment options are carried out in Eu-rope. Landfilling as well as incineration in waste incineration plants of complete appliances, alt-hough practiced in European countries to some degree, is not state-of-the-art and also does not al-low for achieving the recovery targets of the WEEE-Directive. Manual dismantling and removal of the mercury containing backlights require careful handling and may also require air cleaning equipment in order to prevent Hg-emissions. The removed backlights can be further processed in treatment installations for gas discharge. Automated treatment pro-cesses are applied meanwhile by some European companies. Most of them are dry processes per-formed in completely encapsulated facilities, whereby the appliances are crushed initially and mer-cury is removed by filtering the exhaust air with activated carbon filters and into fine sieve fractions. Subsequently automated material sorting is performed applying various sorting technologies, such as magnetic separation, eddy current separation, optical and vibro-sorting, etc. For particular material fractions of flat screens, e.g. the liquid crystal displays containing scarce In-dium, economically feasible recycling technologies have not yet been developed. Small WEEE Small WEEE have to be dismantled manually to achieve appropriate de-pollution. Pre-sorting of small WEEE into certain groups of appliances (e.g. printers, vacuum cleaners, copying equip-ment, IT&T appliances, remaining fraction) turned out to increase working efficiency. Either only hazardous components (batteries, capacitors, LCDs with backlights ink cartridges, as-sembled printed circuit boards) are removed and the remainder is sent to mechanical treatment processes (shredder, post-shredders), or valuable materials such as metals, plastics, or blended materials (cables) are dismantled as well. Mechanical pre-treatment and subsequent removal of hazardous components along conveyor belts is another technology applied in European countries. Different aggregates are in use. Universal cross flow shredders for example consist of a vertical cylinder, wherein two chains are rotating horizontally, which causes disintegration of the applianc-es. Another option is a horizontal rotating drum with metal plates inside. After such a mechanical treatment the disintegrated WEEE are passed to conveyer belts, where hazardous components can be removed manually. Afterwards the material is usually subjected to an automated sorting fa-cility (sieves, magnetic separator). Gas discharge lamps Waste fluorescent tubes containing mercury must be collected separately and treated before dis-posal. The aim of treating lighting equipment is the removal of mercury and the production of metal and glass fractions, which can be introduced into material recycling processes. Encapsulated shredders which are operated under negative pressure and are equipped with appropriate air cleaning equipment (activated carbon filters for separation of mercury) are used. Mercury is re-moved either by heating the material stream (dry processes) or by washing the material. The latter leads to a Hg-enriched sludge, which has to be disposed of. Subsequently the material stream is


subjected to an automated sorting facility. As treatment amounts in general are low, often mobile plants are used. Options for final recovery and disposal for materials derived from WEEE-treatment The first treatment step of WEEE (manual dismantling as well as mechanical treatment) results in a variety of hazardous and non-hazardous material fractions, which require – partly quite sophisticat-ed - further mechanical treatment technologies (recycling, energy recovery or disposal). The follow-ing table summarizes options for further treatment of resulting individual WEEE-components. Table 27: Recycling and disposal options for fractions from WEEE dismantling first treatment step)

Materials / Components Recycling/ Disposal Options

Backlights dedicated lamp treatment plants, landfill for hazardous com-ponents

Batteries sorting, dedicated battery treatment plants

Cables mechanical treatment (cable shredders); Copper: recovery, plastics: recycling or thermal treatment

Capacitors incineration in hazardous waste incineration plants

CFCs thermal treatment (high-temperature incineration)

components containing asbestos land-filling

electron sources from CRTs non-ferrous metal smelters industry

CRT glass (containing Pb or Sr) production of CRT-glass (limited market), fluxing agent in smelting processes (i.e. Pb-smelters), landfilling

fluorescent powder landfilling for hazardous components

Getter landfilling for hazardous components

ink cartridges, toner cartridges re-fill, plastic recycling, thermal treatment

LCD-panels Smelters, incineration for hazardous components

metal scrap (Fe, Al, etc.) metal recovery (steel works, smelters)

printed circuit boards (free of capaci-tors and batteries),

thermal treatment (hazardous waste incineration) , mechani-cal treatment (recovery of metals), metallurgical treatment

Plastics (might contain flame retard-ants and heavy metals)

thermal treatment , plastic sorting

PU (Polyurethane foam) use as an oil binding material, thermal treatment

Metal containing components (trans-formers, engines, drivers, integrated circuits, connectors, compressors)

mechanical treatment, non-ferrous metal smelters

residual, mixed fractions thermal treatment

If in case of small capacitors (for example, start-up and compensation capacitors in washing ma-chines, fluorescent lamps, etc.) due to the production date and on the basis of the labelling, the presence of PCBs cannot be excluded, these are to be classified as potentially PCB-containing ca-pacitors, which should be subject to a thermal treatment in a suitable hazardous waste incinerator (appropriate intermediate storage for export). Due to the wide distribution of PCB-containing small capacitors, the shredder light fraction from the treatment of electronic scrap can contain PCBs to a relevant extent, especially if the pre-treatment of WEEE is not adequate. Shredder fractions are to be subject to an appropriate disposal (thermal treatment). For this (and other) reasons, the con-struction and operation of a thermal treatment facility in Serbia is recommended.


EEE placed on the market of the Republic of Serbia from 1 July 2011 shall not contain the POPs: polybrominated biphenyls (PBB) or polybrominated diphenylethers (PBDE) and other hazardous substances listed in the WEEE Directive (exception: spare parts intended for repair or reuse of EEE).But since end-of-life devices might contain capacitors containing PCBs and plastic containing brominated flame retardants it will be necessary to separate first of all such hazardous substances in the dismantling process,. The same is true with plastic waste from EEE, resulting from TV and monitor housings, power tools, copiers, printers, fax machines and power supplies. In most cases the WEEE waste contains higher quantities of hazardous flame retardants such as polybrominated diphenyl ethers and should be separated and incinerated. Only, plastics from pre-treatment/recovery of electrical and electronic waste, which evidently come from telephone hous-ings (no cell phones), vacuum cleaner housings, housings of kitchen appliances (e.g. coffee ma-chines), or large household appliances (e.g. washing machines, refrigerators) usually contain very low amounts or even no hazardous flame retardants such as polybrominated biphenlyethers. Some EU Member States use specific separation technologies on the basis of infrared and density separation for the mixed plastic fractions resulting from shredders for the purpose of recycling suit-able plastic fractions with almost no or very low PBDE-contents; in any case plastic fractions with higher contents of PBDEs and PBBs must be subject to thermal treatment (in most cases as non-hazardous wastes and only if OctaBDE >5000 ppm – it might be teratogen and therefore is de-clared as hazardous waste). However in the case of plastics containing flame retardants, neither the WEEE Directive, nor the Serbian order specify at which stage the separation shall take place. In some EU Member States the competent authorities allow to separate the plastic fraction of WEEE, with higher amounts of PBDE and PBBs at a later stage, e.g. after shredding, but experience shows that early separation and separate disposal in thermal treatment facilities are easier, cheaper to realize and enable a better separation result. 7.2.8.3 Treatment of ELVs

According to the estimations carried out for this HWMP (see Chapter 6), about 45.600 t of ELV are expected to be generated in Serbia in the future (2020). The treated quantities of ELV reported to SEPA (1.900 t in 2014) are obviously too low. One possi-ble reason for the low figures is that some traders might not yet properly fulfil their reporting obliga-tions. Moreover, it can be assumed, that ELV are often collected by informal collection activities, with the aim to sell spare parts and scrap metal for recycling. End-of-life vehicles might also be shipped abroad informally, or by private persons. Few operators which are registered for metal waste recycling meet the legal regulations for ELV recycling. But these operators have the capacity to recycle ELV in accordance with regulations if they are obliged. These operators constitute the backbone of the future ELV management: For those ELV which find access to the formal sector, hazardous substances and components are not always extracted before the recycling process begins. Parts with use value are extracted in smaller amount, depending of their commercial value. The rest is disposed of in open dumps. The formal ELV sector in Serbia should be enforced by rules, which include obligations with re-spect to dismantling vehicles and separation of hazardous materials and components for further treatment before disposal The operator of the ELV treatment plant must ensure the treatment of such vehicles and disposal of parts that may not be processed, to issue to the owner or person collecting ELV a certificate on taking over the vehicle and submit the certificate on dismantling the ELV to the authority in charge of vehicles registration. The operator must keep records on quantities and treatment of vehicles he has taken over and report the data to the competent authority.


Currently, parts with economic value are extracted in smaller amount, depending on the demand. Up to now the removal of hazardous compounds and components was not required and therefore hazardous substances and components have not always been extracted before the recycling pro-cess of end-of-life vehicles. This means that hazardous substances and components are some-times shredded with all other material of an ELV. This does not only contaminate the metal fraction (ferrous and non-ferrous) , but also – and predominantly because of its physical characteristics - the shredder light fraction. Due to the wide distribution of PCBs containing materials (condensers, gaskets, cavity sealing and underbody protection of motor vehicle) the shredder light fraction from the treatment of car wrecks can contain PCBs to a relevant extent. Presently the management of shredder residues (called fluff fraction) poses a problem in Serbia. The waste are dumped or “land-filled”, no notifications for export have ever been received. Experience shows, that if there is full compliance with the requirements of removal of hazardous substances and components prior to the treatment (shredding) of ELVs, in general shredder light fractions should not be contaminated to an extent rendering them hazardous. In any case shredder light fractions (fluff) should be subject to thermal treatment in waste-to-energy processes (producing heat), otherwise the recycling/recovery target of the ELV Directive won’t be fulfilled. An inspection and adjustment of car dismantler and shredder facilities’ permits to the new legislation is required especially with regard to the separation of hazardous components from the ELVs, compliance with the technical minimum requirements for treatment of ELVs and an environ-mentally-sound management of the shredder light fractions (fluff). For full compliance with the ELV Directive the dismantling facility in combination with the shredding facilities are obliged to reach the following recycling targets: 95 % of recovery (material and energetic re-use) and

85 % of recycling (material re-use only) of the ELVs accepted at the facility annually.

Processing of ELVs includes the following stages:

Depollution: the removal of hazardous and toxic fluids of the vehicle and the removal or neutrali-zation of hazardous parts of the vehicle, such as airbags.

Dismantling: can be either partial (removal of liquids, battery, bumpers, glasses, doors, tyres and also the engine), or complete

Shredding: separation of materials, into 1) ferrous metals, 2) non-ferrous metals and 3) Automo-tive Shredder Residue (ASR)

Post shredding technologies: Final disposal of ASR or Thermal/Mechanical treatment of ASR (Recovery of materials/fuels/ Energy recovery).


Figure 16: Compartments and technical components of mechanical treatment facilities of ELV.

The alternative systems/ management scenarios of ELVs, are as follows:

Management System 1: Complete dismantling/ shredding/ separation-recovery of ferrous and non-ferrous metals/ landfill of ASR:

Management System 2: Complete dismantling/ shredding/ separation-recovery of ferrous and non-ferrous metals/ treatment of ASR

Complete depollution & dismantling of ELVs

The first stage of management includes the complete dismantling of vehicle, more specific the re-moval of any residues of fuel, fluids and lubricants, the removal of parts such as the engine, igni-tion, batteries, tyres and transmission system, in order to repair and reuse. Moreover, materials that have economic value, such as lead in batteries or/ and the precious metals on catalysts, are removed and resold.

The dismantling remaining part (hulk) includes the skeleton of the vehicle, part of the electronics, plastics (seats, dashboard etc.), glass and rubber. The hulk leads for shredding, further separation and also management of the flows resulting from shredding.

The percentage of ASR is increasing compared to the total weight of ELVs, because the plastic content of vehicles increases in combination with the metal parts.

The shredded vehicle consists of about 69% of ferrous metals and 2,7% of non-ferrous metals. Therefore, the recovered metals consist the 71,8% of the ELV, after its shredding. The recovery of ferrous metals and metals overall, approaches the 38,7% and 40,2% respectively of the initial av-erage weight of a new vehicle. Moreover, the shredder dust consists of fluff and soil and sand and consist of about 28% of the total Automotive Shredder Residue - ASR and the 15,8% of the aver-age weight of a new vehicle.


Landfill of Automotive Shredder Residue (ASR)

The ASR is usually mixed with other shredding residues and is led to final disposal areas. The fact that ASR contains hazardous substances (even in small quantities) leads in the search for other practices of management. Priority is given to the materials recycling (mostly plastic) of ASR. The problem of this practice is the different chemical composition and behaviour of the type of plastic used and the high cost of the method.

The main environmental pressures emanating from landfills is the pollution of surface and ground water with toxic substances and nutrients extracting from landfills, the gaseous emissions and the loss of land converted to landfills. Furthermore, landfills indirectly represent the loss of natural re-sources and require substantial expenses for their maintenance and restoration after their end-of-life.

The gases emitted from landfills, and more specific from the biodegradation of organic compounds, are mainly methane and carbon dioxide. The contribution of methane to the greenhouse effect is 50 times greater than that of CO2, for a period of 20 years. It is dangerous to cause fire and explo-sions at landfills, because of the methane.

In order to avoid landfilling of ASR, is recommended to increase the cost of landfilling, in which way that the treatment of ASR can became a more viable as an alternative solution, because it can bring out valuable materials on one hand and reduces the mass and volume of ASR while it recov-ers energy on the other hand.

Mechanical treatment of Automotive Shredder Residue (ASR)

Mechanical separation processes are based on the different physical properties of the materials within ASR. The main fractions of ASR include plastics, fibres, rubber, and residual metals.

The different properties of these fractions allow for mechanical separation methods including:

trommel size separation (a screened cylinder that rotates and separates materials based on size);

vibration sieving (separates different sized fractions of the ASR using differing mesh sizes);

air classification (separates sieved fractions by size and density);

sink and float method (separates fractions based on density);

eddy current separation system (allows for non-ferrous metal separation by using a spinning ed-dy current rotor to repel the non-ferrous metals from the ASR stream);

magnetic separation (iron is easily separated from non-ferrous materials with a magnet).

The thermal treatment of solid waste includes all the processes of transformation of their content in gaseous, liquid and solid products, while the subsequent release of thermal energy. The main methods of thermal treatment are incineration, combustion and gasification. The thermal treatment reduces the volume of wastes, transforms a large part of them to inert materials and reuses their energy.


Incineration Automotive Shredder Residue (ASR)

The incineration is the union of chemical compounds of solid wastes with oxygen. The wastes that lead for incineration must fulfil certain requirements for their composition, calorific value and humid-ity in order to allow autonomous combustion (i.e. not to be affected by another fuel). Physical and chemical processes take place during combustion such as curing, thermal division, degasification etc. For complete combustion, must fulfil certain requirements, such as correct mixture of fuel and oxygen, suitable temperature in the incinerator, sufficient time of waste in the incinerator, continu-ous removal of gases and residues of combustion etc. The reduction of waste volume achieved during incineration is about 30% of the total weight of waste (for every tonne incinerated, there are produced 300 kg of ash).

The combustion residue is steadier than the initial material and thus it is easier to be disposed for landfill or to be recycled. In many incineration facilities part of the produced energy is recovered. However, incineration produces gaseous emissions, waste water (as a result of quench ash and cooling of gas procedures) and inorganic ash.

The gaseous emissions consist of nitrogen, CO, CO2, H2O, ΝΟx and SO 2, substances which are products of combustion and other substances depending from the composition of the waste incin-erated. The most common gas derivatives are acid gases, polycyclic aromatic hydrocarbons (ΡΑΗ), dioxins (PCDD), furans (PCDF), dust and oxides of heavy metals. The gas purification pro-duces a secondary residue, which is usually considered as hazardous waste.

The high cost of ASR landfill (treated as hazardous waste) makes the incineration an alternative solution to be considered solution, because it reduces the mass and volume of ASR while it recov-ers energy. It should be checked for the presence of heavy metals in suspended particles produced and ash remaining in the bottom of incinerator.

Other pollutants produced during incineration of polymers are, also, measured. More specific, thermal division of PVC leads to the formation of HCl which starts with temperatures of about 373 Κ. Also, the combustion of rubber at temperatures over 773 Κ produces sulphur compounds such as hydrogen sulphide (H2S) and sulphur dioxide (SO2). Finally, polyurethane contains a significant proportion of nitrogen thus during incineration as it is possible the formation of nitrogen oxides such as nitric oxide (ΝΟ) and nitrogen dioxide (ΝΟ2) or even hydrogen cyanide (HCN).

7.2.9 Options for the treatment, recovery and disposal of PCB waste and other wastes containing POPs

PCB waste The PCB Directive (96/59/EC) set the following requierements regarding elimination of PCB waste and PCB contaminated equipment: 1. Member States shall take the necessary measures to ensure that used PCBs are disposed of

and PCBs and equipment containing PCBs are decontaminated or disposed of as soon as possible.

2. Member States shall, within three years of the adoption of this Directive: - Draw up plans for the decontamination and/or disposal of inventoried equipment and the

PCBs contained therein and - Establish programs for the disposal/decontamination of equipment containing PCBs - Ensure that used PCBs are disposed of and PCBs and equipment containing PCBs are

decontaminated or disposed of as soon as possible.


Therefore, according to Article 52 of the Serbian Waste Management Act, for PCB waste, being collected separately the following is prohibited: transformer filling with PCB;

reuse of PCB waste;

PCB recycling from PCB waste;

temporary storage of PCB, PCB waste or PCB-containing equipment for a period longer than 24 months prior to their disposal or decontamination;

incineration of PCB or PCB waste on ships;

use of PCB-containing equipment if they are not in proper operating condition or if they leak.

This Law, for the first time, defines obligations of the PCB owners, PCB waste or PCB-containing equipment: the owner of PCB and PCB waste is obliged to organize its disposal, i.e. decontamination;

the owner of PCB-containing equipment in use or a equipment possibly contaminated with PCB, is obliged to examine a PCB content using the services of accredited laboratory authorized to conduct waste analysis;

the owner of equipment containing more than 5 dm3 of PCB is obliged to report to the MEMSP and to propose a replacement plan, i.e. a plan of its disposal and decontamination, to ensure its disposal and decontamination.

There is no facility for PCB waste treatment in Serbia and this waste is exported for treatment. There are several authorized private companies which perform taking over and export of PCB waste for treatment in compliance with Law on Ratification of the Basel Convention. At present, there are no locations intended for permanent storage and decontamination of PCB-contaminated equipment and waste, nor facilities for PCB-based fluid degradation in Serbia. According to the EU POPs Regulation, residues from iron- and steel-making processes or non-ferrous metallurgy (e.g. dusts from gas cleaning) containing higher amounts of dioxins may be sub-ject to metal recovery only, if recycling/recovery facilities meet as a minimum the emission limit val-ues for PCDDs and PCDFs of 0,1ng I-TEQ/m³. The R4 operation “recycling/reclamation of metals and metal compounds” is not allowed for PCBs-containing metal waste; industrial emission limits for smelters in Serbia should be checked, espe-cially with regard to PCDD/PCDF emissions and, if necessary, amended in the future according to BAT (see the relevant BREF documents). The requirement for compliance with this PCDD/PCDF emission limit has to be obeyed also in case of export or import of residues from iron- and steel-making processes or non-ferrous metallurgy (e.g. dusts from gas cleaning) containing higher amounts of dioxins. In such cases high temperature incineration is available to completely destroy such compounds. The project “Environmentally Sound Management and Final Disposal of PCBs” will choose the best solution for management and disposal of PCB in Serbia. The main issue for selection of PCB treatment technology is to set the requirements that the treatment technology should meet, based on their applicability and relevance to the country strategy, existing and planned programs, and PCB owners’ need and compliance with the BAT and BEP standards. Cost estimate for the full im-plementation of Directive will be provided through the project. It is possible that a transitional period for full implementation will be necessary. Presently most of the collected waste oils (motor-oils) are incinerated in cement kilns. The addition of PCB/PCT-oils, halogens, Arsenic, Mercury, Cadmium and Lead are clearly prohibited. PCB con-taminated equipment and PCB-oils must find other environmentally sound elimination and disposal solutions.


Various methods of decontamination of PCBs oil have been shown to be technically feasible (e.g. hydrogenation, reduction with molten sodium, use of selective adsorbents, replacement by PEG etc.), while economic viability of the selected method will depend on the type (voltage level and power rating) and age of equipment to be decontaminated, the level of PCB concentration, as well as the overall cost for equipment replacement and the available budget. Incineration under high temperature in specialized hazardous waste incineration plants are the only promising technology to destroy PCB efficiently for neat PCB fluids or fluids containing high concentrations of PCBs . In order to minimize waste quantities to be eliminated in such way, PCB-oil might be separated from transformers and other equipment by certain techniques. But simple washing of PCBs-containing electrical equipment with a solvent and subsequent treatment with a shredder is not permitted as substantial quantities of PCBs-containing oil remain in the coil and in the insulation, which leads to dioxin formation during shredding and contamination of the shredded waste with PCBs.

Figure 17:Fig Technical components of treatment facilities for PCB contaminated transformers (Tunisia)

Before recovery of the metal parts from PCBs-bearing electrical equipment, complete dismantling (unwinding copper wires, dismantling of the sheet metal plates, extracting oil imbued insulating pa-pers etc.) and decontamination of the metal parts are therefore necessary. As for these pre-treatment processes, all these operations are to be carried out in a suitable plant with a secure black zone. Special precautions are necessary regarding the possible release of PCBs (airlock, treatment of exhausted air etc.). The recovery of insufficiently decontaminated metals by shredding or in a smelter may lead to high PCDD/PCDF-emissions, even when the PCB-content is below 50 ppm/kg. The general limit value of 50 ppm is not sufficient for an environmentally sound metal re-cycling. An additional limit value expressed as mg/m² should be introduced.


Retro-filling of PCB-free fluids to equipment that originally contained PCB should not be allowed and must clearly be forbidden.Alternatively, in the Ministerial Order on PCBs a stipulation should be implemented that in case of retro-filling of PCBs-equipment with PCBs-free fluids, analysis of such fluids shall be required, as it is known that PCB is “leaching” from remaining PCBs oil in the coil (transformer coil, transformer plates, condenser plates) and will contaminate the originally PCBs-free replacement fluid. Depending on the results of these analyses the appropriate treatment is to be foreseen in compliance with the Ministerial Order on PCBs. Due to the wide distribution of PCBs-containing small capacitors (e.g. start-up and compensation capacitors in washing machines, fluorescent lamps, etc.) the shredder light fraction from the treat-ment of WEEE (especially of white end-of-life-products) may contain PCBs to a relevant extent, especially if the pre-treatment (sorting, partly dismantling) of WEEE is not adequate; this might dis-rupt the recycling of WEEE decisively. In other words: If the production date and the labelling indi-cate the presence of PCBs in such capacitors these capacitors should be classified as potentially PCB-containing capacitors, which shall be subject to strict separation from WEEE and a thermal treatment in a suitable hazardous waste incinerator or an appropriate intermediate storage for ex-port respectively. PCB not being separated from WEEE will be accumulated – after shredding and further separation - in the shredder light fraction, where it is absorbed from fluffy textile and plastic material. This means also: Shredder light fractions (fluff) should be subject to thermal treatment (incineration) or energetic re use in rotary kilns under high temperature. Adequate dismantling prior to the shredding process can reduce the amount of fluff and increase the recycling quota. For all these purposes the establishment and operation of at least one thermal treatment facility in Serbia is recommended. An adjustment of car dismantler and shredder facility’s permits to the new legislation is required especially with regard to the practical performance of separation of hazard-ous components and compliance with the technical minimum requirements for treatment of ELVs and WEEE as well as the environmentally sound management of the shredder light fractions (fluff). As up to now even illegal dumping of shredder light fractions took place. Alternatively and in a short term, landfilling to authorized landfills could be an intermediate solution only if such shredder frac-tions are identified as non-hazardous waste. This decision shall be based on analyses of the shredder fractions (= simultaneously check of compliance with the pre-treatment requirements laid down in the EU legislation for WEEE and ELVs). PCB-containing gaskets and sealants from C&D waste should be separated and subject to thermal treatment in hazardous waste incineration plants. Due to the relatively small quantities per year, PCB wastes cannot justify the establishment of a hazardous waste incinerator in Serbia; but once – due to other predominant waste types – a hazardous waste incinerator is put in place, PCB wastes from C&D waste will continuously be eliminated there. Mineral fractions (e-g- PCBs-containing concrete or plaster) can be exported for storage in suitable underground mines in accordance with Annex V to the POPs Regulation. This needs export to abroad. Due to the wide distribution of PCBs-containing small capacitors in WEEE the shredder light frac-tion from the treatment of electronic scrap (especially of white goods) may contain PCBs to a rele-vant extent, especially if the pre-treatment (sorting, partly dismantling) of WEEE is not adequate. In any case, shredder fractions (fluff) should be subject to thermal treatment (incineration), also considering the fulfilment of the recycling/recovery quota of the ELVs Directive. For this purpose the erection and operation of at least one thermal treatment facility in Serbia is recommended.


Figure 18: Example of PCB treatment process in former German ABB facility Dortmund.

POPs waste other than PCB POPs substances are banned from use and must be removed. In Serbia there are neither incinera-tion facilities nor landfills and underground storage mines for POPs waste. Due to a lack of treat-ment facilities for hazardous wastes presently, POP waste (e.g. PCB-wastes, pesticides, packaging contaminated with POPs) are stored in intermediate storage facilities for the purpose of export to adequate disposal facilities (hazardous waste incinerators) abroad. The establishment of new stor-age facilities complying with the-state-of-the-art (maybe state-owed) should be considered. Physico-chemical treatment and use as a secondary fuel (i.e. incineration) are the most frequent treatment options applied to POPs waste. EU standards for incineration and industrial co-incineration of waste and BAT notes guarantee stringent limits for emissions of unintentionally pro-duced POPs such as dioxins from incineration process.. A short term solution for specific POP wastes could be the incineration in cement kilns in Serbia. Cement kilns provide temperature profiles and gas residence times which are comparable to haz-ardous waste incinerators. According to literature sources, the destruction efficiencies of 99.9999% have been demonstrated in the-state-of-the-art cement kilns. The incineration of low levels of PCBs and POPs waste (chlorine limitation of 1%) in the main firing system seems to be feasible, if the facility’s permit allows the input of such waste up to a specific limit and if it is complied with the emission limit values according to the WID and IED. Depending on the technology of the cement plant, suitable waste with even higher PCB/POPs con-tent than specified in Annex IV of the POPs Regulation may be incinerated as the high tempera-tures in cement kilns normally destroys POPs and the formation rate of dioxins in cement kilns is low. WID and IED respectively establish the emission limit values for facilities used for thermal treatment of waste (e.g. cement kilns). This Directive has also been transposed into national Serbi-an legislation by the adoption of Regulation on types of waste subject to thermal treatment, the conditions and criteria for determining the location, technical and technological requirements for the design, construction, equipping and operation of the facility for thermal treatment of waste, the treatment of residue after incineration (Official Gazette of the Republic of Serbia, no. 102/2010 and 50/2012).


Cement plants in Serbia, performing thermal treatment of hazardous waste, have all the necessary permits for waste management determined by the Law on Waste Management ("Off. Gazette of RS", Nos. 36/2009, 88/2010 and 14/2016), and fully meet the limit values for emissions of air pollu-tants for co-incineration of waste determined in Part 1 of Annex 4, the above mentioned Regula-tion. It is recommended to assess the present facility’s permits in detail with regard to the possible incin-eration of POPs waste. Monitoring and evaluation of the emissions by external independent and qualified experts within a trial incineration of POP waste should be required, especially if wastes with higher POPs contents than specified in Annex IV of the POPs Regulation shall be incinerated. The expertise should prove the complete destruction of PCB and POPs. In case of input of wastes exceeding the low limit of PCB (> 50 ppm) any exemption from the operational conditions of the fa-cility with regard to the temperature or residence time is not admissible. Waste oil is excluded from either energetic or material re-use, if exceeding the low POPs content limit of 50 ppm (i.e. 50 mg/kg). However, such oils/wastes can be incinerated properly in the firing systems of a cement kiln. Fuels derived from residues (RDF) may contain up to 50 ppm of PCBs. In case of waste exceeding 50 ppm of PCBs, the incineration has to be qualified as a disposal op-eration (D10: incineration on land). In Serbia there are standards for RDF (“solid recovery fuels”) as well. Special attention has to be given to the limitation of mercury in RDF due to the former use of Hg-additives in lubricants and cutting oil. A recommended input limitation for mercury could be 0,5 mg Hg/kg (related to a lower calorific value of 25 MJ/kg).. Two cement plants in Serbia have permits for thermal treatment of RDF waste materials, ie for re-covery of energy from waste in the cement production process, issued in accordance with the Law.

For the purposes of placing on the market produced standardized RDF fuel, it is necessary to in-clude mandatory application of the provisions of those standards in national legislation:

SRPS EN 15358:2012-Solid recovered fuels (SRF) - Quality management systems - Particular requirements for their application to the production of solid recovered fuels

SRPS EN 15359:2012-Solid recovered fuels (SRF) - Specifications and classes

The incineration of specific low POPs wastes in coal power stations could be evaluated on a case by case basis, depending on the flue gas cleaning system. In any case the compliance with the emission limits laid down in the WID is a necessary prerequisite. In general, however, the flue gas cleaning system of coal power plants is not adequate for the incineration of POPs waste. It is ex-pected that coal thermal power plants would be interested in the thermal treatment of specific waste streams but the existing ones do not comply with the EU standards for co-incineration yet. Therefore the incineration of even low POPs-wastes in coal power stations in Serbia is no option at the moment. Ban on landfilling of wastes with a TOC >5% (6000 kJ/kg), like in Austria and Germany and ban on landfilling of non-treated hazardous waste contributes to environmentally sound POPs waste man-agement, because organic waste fractions from shredding or dismantling need to be treated in thermal treatment facilities. Quality standards for waste derived fuels are useful as well, limiting the allowed PCBs-content of solvents and waste oils used as refuse derived fuels (RDF). In Serbia, underground mines are available, which may be authorized for permanent storage of specific POPs waste in accordance with Annex V of the EU POPs Regulation, if proof of their ap-propriateness for storage of hazardous waste can be produced (especially proof of long term safe-ty). However, permanent underground storage is accepted as a disposal option under the Stock-holm Convention only if the POPs are permanently separated from the environment, which might exclude mines liable to pit water. Also mines needing a permanent ventilation to avoid an explosive atmosphere (coal mines) are unsuitable as permanent storage sites for POPs wastes.


For POPs packaging containers mainly made of metals, plastics and metal/cardboard have been used; in some cases the composition of this packaging is not clearly known. Some companies en-visage washing of packaging containing POPs for the purpose of subsequent incineration of the washed empty packaging in cement kilns. Bur washing and cleaning of POPs packaging waste should be prohibited in Serbia as long as adequate wastewater purification standards are lacking. With reference to the POPs regulations the cleaning/re-use of washed plastic container as well as the material recycling of this plastic cannot be recommended. Most of the POPs are highly soluble in hydrocarbons and migrate into plastics especially PP and PE. The washing results in contami-nated water or solvents which again need a specific treatment as POPs waste. Therefore, thermal treatment of POPs packaging in adequate facilities (export to high temperature incineration facili-ties) is recommended.

7.2.10 Conclusions on the need of new installations

Assuming the results from chapter 6 on waste quantity estimations for 2020 and comparing these quantities with the infrastructure needed, the following conclusions concerning new installations for hazardous waste management in Serbia can be deduced: 1. Establishment of separate collection and storage of hazardous household waste within

municipalities, operated mainly by municipalities in the context of “recycling yards”; regular evacuation to regional storage facilities.

2. Construction of regional storage facilities for hazardous waste in 5 regions of Serbia, operated mainly by private operators of the waste management sector, often in the context of treatment facilities; transfer to treatment facilities or to export.

3. Construction of a facility for physical- chemical treatment of inorganic and organic liquid haz-ardous waste and sludge combined with storage units for liquid and pasty industrial special waste streams like solvents, acids, bases etc. on the one hand and oily wastes and solvents on the other; evacuation of residues to further treatment (RDF preparation), to landfilling facilities or to export.

4. Establishment of capacities for incineration of organic industrial and medical waste, eventually combined with capacities for the preparation of residues derived fuels (RDF) from organic hazardous waste streams.

5. Establishment of capacities for landfilling of inorganic industrial hazardous waste eventually combined with capacities for the solidification of pasty hazardous waste streams.

6. Creation of a management system (collection, storage, dismantling and other treatment, final disposal) for all special waste streams regulated by European and national waste legislation. Such hazardous waste streams are as follows: used batteries and accumulators, waste oils, end-of-life-vehicles (ELV), waste from electric and electronic equipment (WEEE), POP-wastes and PCB-waste, medical waste, asbestos from C&D sector, hazardous packaging waste.


Figure 19: Conclusions concerning new HWM facilities and related capacities

A strategic framework for implementation of Art. 16 of the Waste Framework Directive is provided for in the draft amendment to the National Waste Management Strategy (hereinafter draft amended NWMS) for Serbia covering the period till 2019. It is foresees that the waste management infra-structure shall be developed in stages with the establishment of: basic components of the regional waste management systems in first stage

additional components or developing more sophisticated solutions during next stages.


The priority should be given to: the development of source separation of hazardous waste in households, commerce and indus-

try

the development of regional storage capacities,

the development of physical-chemical treatment capacities for inorganic hazardous waste for industry,

the development of physical-chemical treatment capacities for organic hazardous waste name-ly solvents, oily sludge and oil-water mixtures and subsequent preparation of residues (waste) derived fuels RDF for cement kilns and other thermal processes and

appropriate capacities for the disposal of residual inorganic hazardous waste fractions in haz-ardous waste landfills, partly combined with solidification processes.

One of the Long-term objectives ( > 2019) is the implementation of an integrated and completed system of separate collection and treatment of hazardous waste from households and industry. This long-term system includes the establishment of above mentioned adequate collection and transport facilities for hazardous waste from households, commerce and industry, construction of five regional intermediate storages for hazardous waste in order to prepare it for further transport to treatment facilities or for export, the construction of one plant for physical-chemical treatment of in-organic and organic liquid and pasty hazardous waste types combined with a unit for the produc-tion of RDF, the establishment of thermal treatment capacities through construction of one incinera-tor for hazardous waste from industry and medical sector combined with co-incineration capacities in other thermal units like cement kilns, and one central hazardous waste landfill that might be combined with a unit for solidification of pasty wastes. If a potential operator plans to establish a waste management facility, it could be helpful to use such sites that are part of an existing industrial area or to reactivate former industrial sites. In gen-eral, the legal and environmental conditions for such industrial areas have been checked in ad-vance and usually have a better acceptance in the public. Subsidies for the remediation of aban-doned industrial sites could develop double benefits and display the main goal of Serbia concern-ing these sites. Former mining areas could serve in the same manner. Establishment of separate collection and storage of hazardous household waste (2017-2019) within municipalities, regular transfer to regional storage facilities

The implementation of separate collection schemes is still in its infancy in Serbia. The infrastructure for source separation and recycling must be diversified and intensified; this is a pre-condition for further success in waste recycling. Collection points for separate collection of recyclable waste and hazardous household waste within the municipalities have a significant role in the overall municipal waste management system, be-cause they serve as a connection between the local self-government unit and the citizens. This im-plies that the locations for the establishment of the centers in which the activities on the separated collection of waste are carried out should be provided by the local self-government units. In bigger cities there should be at least two, in smaller cities there must be at least one such collection point. Hazardous and non-hazardous municipal waste should be collected in the same collection sites. Citizens must be allowed to bring both types of waste to such collection points free of charge. In the cities, it shall be necessary to determine accessible locations for the separate collection schemes und to manage opening hours in a citizen friendly manner. Due to the small amounts of collected hazardous waste quantities within these general municipal collection points and due to the regular evacuation of such hazardous waste to intermediate regional collection centers it should be possible to find such locations without complications.


Also locations on existing municipal waste disposal sites (dumps) might be transformed to collec-tion points; in this case the plans must be harmonized with previously approved rehabilitation pro-jects. The units for the collection of hazardous household waste will be equipped with containers for the collection of batteries, accumulators, small quantities of pharmaceutical waste, stained packaging from paints and varnishes, detergents, pesticides, waste oil, WEEE, titres etc. These units are inte-grated into the centres for separated collection of recyclable waste and need especially well trained staff. The “collection points” for hazardous household waste could also be mobile collection units. This means that in remote areas or in favor of less mobile citizens once or twice per year a truck collects such hazardous household waste. This truck must be appropriately equipped and driven by trained staff. In this case the citizens would be informed about location and opening hours of the mobile collection unit. Construction of regional storage facilities for hazardous waste in 5 regions of Serbia (2018), regular transfer to treatment facilities or to export

In addition to the local municipal collection points for hazardous and recyclable waste, it shall be necessary to establish regional storages for hazardous waste, intended for safe storage and preparation of such waste for further treatment or export. Such facilities fulfill all requirements nec-essary for safe handling and storage of hazardous waste like underground sealing, in-house stor-age, labeling and packaging rules, explosion and fire abatement technology, ventilation etc. Such hazardous waste storage facilities should be operated by private enterprises, experienced in collection, transport, packaging, handling and/or treatment of hazardous waste and are driven ac-cording to the rules of the market. Therefore such regional storage facilities might be part of haz-ardous waste treatment facilities or work independently. Experience from other countries tell us that such storage facilities often are accompanied by basic pre-treatment processes for the collected waste streams like gravity separation of liquids in the tanks, filtering, conditioning of liquids to meet certain calorific values, ventilation and collection of emanating gases etc. Therefore such regional storage facilities have the function of transfer stations equipped for tem-porary storage, repackaging, reassembling to larger transport units, preparation for transport and further treatment and reload on bigger trucks for distance transport or even export . The transfer station shall also be the place where the hazardous household waste from municipal collection units is unloaded from the vehicles, inspected with optional separation of inconvenient waste types, reloaded into bigger vehicles and transported for further treatment. Transport of waste by a higher-capacity vehicle significantly reduces the long-distance transfer costs. Potential locations for regional waste management centers, criteria and guidelines for their founda-tion shall be planned through spatial plans of authorities, while the definite locations will be select-ed by the future operator after the investigation works and carrying out the procedure of environ-mental impact assessment. In order to define potential locations for the construction of the men-tioned storages and to give certain security for the private investment, it shall be necessary to ana-lyze the regional needs in terms of origin, type and quantities of hazardous waste to be stored. Construction of such regional storages for hazardous waste is foreseen for the following adminis-trative counties: Srednjebanatski administrative county;

Podunavski administrative county;

Mačvanski administrative county;

Moravički administrative county;

Nišavski administrative county.


But final decision is depending on more detailed planning steps concerning regional needs and will-ingness of private operators. Because of the economic value, there is a very high recovery rate of used automotive lead batteries and accumulators in Serbia. This indicates that source separation is possible in industry and commerce. Extension of the source separation for recyclable and for haz-ardous waste in commerce and industry is necessary in order to improve the efficiency of all other waste management steps that follow. In other words, without source separation waste manage-ment options get much more expensive and technically much more sophisticated because such dif-ficult mixtures are difficult to separate in a later stage of evacuation. Therefore activities must focus first of all to the: Development of a set of economic instruments to support source separation and recycling in in-

dustry and commerce; and the

Development of technical solutions and specifications for the equipment for source separation within the collection and storage sites.

Construction of a facility for physical- chemical treatment of liquid hazardous waste and sludge combined with storage units for liquid and pasty industrial special waste streams like solvents, acids, bases etc. (2019)

Having in mind the data concerning type and quantity of generated hazardous waste in Serbia and considering the future changes in the industrial sectors of the Republic of Serbia, the need for the construction and operation of a physical-chemical treatment facility for hazardous waste is obvious. As a part of the project “Technical assistance in preparation of documentation for the construction of the facility for physical-chemical treatment of hazardous waste”, funded from the EU pre-accession funds – 2009 program cycle, a feasibility study had been develop to take into considera-tion several locations for construction of such a facility for physical-chemical treatment in Central Serbia the need was focused on the region that convers Moravički, Šumadijski, Pomoravski, Raški and Rasinski administrative county. Private investment should be stimulated by public securities in order to overcome economic uncertainties that usually accompany such investments in comparable situation. The capacity of the facility for physical-chemical treatment of hazardous waste should cover the need of some 50.000 tons per year based on the overall quantity of appropriate hazardous waste types generated in the Republic of Serbia annually. The facility should comprise all necessary (and commonly established) elements for the treatment of organic and inorganic hazardous waste. An appropriate laboratory is an integral part of such installations. Capacity shoould be developed stepwise and in a modular way. It is up to the private investor to decide if other elements like solvents distillation facilities or silver electrolysis (for photographic liquid residues) should be added and if this center includes a landfill with cassettes for hazardous and nonhazardous waste. Technical documents needed for the authorization and construction of this facility shall define for all units within the facility the appropriate technology and capacity needed, as well as organizational and operational characteristics of the facility, all this in compliance with the international standards and the state-of-the-art like defined in the BAT reference documents for waste treatment..


Establishment of capacities for incineration of organic industrial and medical waste (2022) eventally combined with capacities for the preparation of residues derived fuels (RDF) from pasty hazardous waste streams

Incineration plants for hazardous industrial waste, including medical shall be considered in the forthcoming period in accordance with the needs and capacities of the existing facilities (cement plants, thermal power plants, heating plants, etc.). Needed capacities for RDF re-use from waste oil amounts to approx. 22.000 tons per year and additional capacities for RDF valorization resorting from sorting, dismantling and physical-chemical treatment facilities will amount to approximately 10.000 tons per year additionally. Production capacities of the existing facilities with the option of thermal treatment of waste (cement plants, steel mills, thermal power plants), may be used for co-incineration of certain types of waste, if they meet all the requirements prescribed by legal regulation. But due to the urgent need of addi-tional capacities for quite a number of organic hazardous waste, the possibilities and conditions for using the existing plants and installations should be promoted actively by the competent authori-ties. It must be a concern for the whole Serbian industry to find a way how and where to find oppor-tunities for such energetic use of hazardous waste in industrial processes. The preparation of per-mits should begin at once in close cooperation between competent authorities and industry defining the requirements that must be met for the energetic use of such waste. Related ad-hoc measures to be accomplished are: 1. Public awareness campaign regarding the benefits of using waste as an alternative fuel and as an alternative raw material 2. Feasibility study for the use of waste as an alternative fuel (oil waste and oil sludge, tires, sol-vents, other organic waste etc.) 3. To draft technical standards for the use of waste as fuel 4. To develop existing production facilities and technology (BAT application) for the usage of waste as an alternative fuel In the long-term period and with more data available about the related need, Serbia will focus on the establishment of a central plant for hazardous and medical waste incineration. Residues like packaging waste polluted with hazardous substances (e.g packaging waste polluted with pesti-cides, chemical substances, PCBs etc.) that must not be burnt in cement plants will need such in-cineration otherwise these wastes have to be exported for a long time.

Establishment of capacities for landfilling of inorganic industrial hazardous waste eventual-ly combined with capacities for the solidification of pasty hazardous waste streams

The mechanisms for resolving historical pollution, and/or removal of damage to environment due to inadequate waste management should be developed. It is necessary that the sites polluted with hazardous waste should be identified, risk assessment should be made and the priorities for reha-bilitation identified. It is also necessary that the obligations of all participants should be identified (Republic, province, local self-government, operator, owner) for carrying out the rehabilitation pro-cess. The regional waste management plans will precisely define waste management needs in conformi-ty with the EU Directives and with guidelines from the National Waste Management Strategy. It is of particular importance to establish these guidelines on the basis of the very stringent require-ments of the EU Directive 99/31/ЕС on landfills and to follow the new criteria for evaluation and choice of landfill locations in conformity with these regulations. The design studies on waste type, waste quantities and landfill technology must be harmonized with the EU Directive on landfills. Other basic objectives in the development of the regional concepts shall be rational use of space as a resource and reduction in costs of waste management.


Present estimations based on prognostic numbers of waste generation amount to 28.000 to 38.000per year to be landfilled in hazardous waste landfill units. The quantity is highly influenced by mineral residues deriving from mining activities (approx. 60.000 tons) which apparently gen-erate waste with hazardous properties; they are not included in above mentioned capacity need. The quantity will also be influenced by wastes related to removal of historical pollution and remedi-ation of contaminated sites. Experience from other EU MS shows that the expected quantity of mineral hazardous residues generated by multiple industrial and commercial activities could be even higher than above mentioned prognostics implicate. Asbestos arising from C&D waste is not added in this amount, because such waste can landfilled in lower classes of landfills e.g. in sepa-rate cells of municipal landfills. It is out of question that a hazardous landfill is needed for the multiple types of mineral and mineral-ized hazardous wastes: The more the hazardous and non-hazardous waste management infra-structure proceeds, the more increases the amount of residues from waste treatment processes that need an appropriate further disposal. The more the rehabilitation of contaminated sites pro-ceeds, the more increases the amount of treatment residues that need hazardous landfilling. It has been identified that urgent hot spots contaminated by hazardous waste to be rehabilitated are in Bor and Pančevo, primarily. It could be wise to combine such rehabilitation works with the installa-tion of a hazardous waste landfill. Other possibility – in a more regional approach - could be to in-tegrate hazardous waste landfill cells in other (municipal or industrial) landfills.

Creation of a management system (collection, storage, dismantling and other treatment, fi-nal disposal) for special waste streams

The management system for special waste streams like used batteries and accumulators, waste oils, ELV and WEEE comprises: source separation in municipalities, industry and commerce,

special waste stream collection and transport to intermediate storage facilities,

dismantling and re-conditioning centers for material separation and selected secondary raw ma-terial extraction

adequate treatment facilities for residual waste treatment (e.g. shredding and sorting) and poten-tially facilities for advanced secondary raw material extraction technologies.

capacities for final treatment in cement plants, incinerators and landfills for hazardous residues to be disposed of.

The system should enable to fulfill the EU-collection targets e.g. for WEEE, batteries and accumu-lators and ELV. The system for the management of speacial waste streams should consist of the following elements: 1. Construction of collection points in municipalities suitable for the collection of hazardous

household waste (solvents, paints, WEEE, batteries and accumulators, waste oil etc.): 2. Providing state-of-the-art treatment capacities for pre-treatment of waste oils either by up-

grading existing capacities or by constructing new plants; 3. Construction of facilities for sorting of used portable batteries and accumulators; 4. Maintaining sufficient capacities for dismantling and pretreatment of WEEE 5. Improvement of the system of collection, dismantling and recycling of ELV: 6. Establishment of economic instruments to encourage re- use and recycling of waste material.


Certain waste streams falling into this category follow their own principles due to separate projects on a national level; this is the case for medical and pharmaceutical waste and for

POP’s and PCB waste.

Establishment of waste management system for medical and pharmaceutical waste 1. To draft a national program for medical waste management, to define the quantity and types

of medical waste 2. To revise and adopt regulations regarding medical and pharmaceutical waste handling 3. To train medical staff to separate medical waste 4. To draft waste management plans in all health care institutions and veterinary organizations

Establishment of waste management system for POPs and PCB waste Such hazardous wastes that cannot be treated in the country should be stored temporary in re-gional storage facilities like mentioned above and prepared for export to authorized plants abroad. These temporary storages should serve to an exporter of hazardous waste only for collection and re-packing of hazardous waste intended for export. On a long term, only a hazardous waste incin-erator can solve this problem on a national level.


7.3 Estimated investment and operational costs for appropriate waste management options

This financial estimation includes the costs of the implementation of the facilities mentioned above, which is: Construction and operation of local collection points on municipal level accomplishing the

function as collection points of hazardous and non-hazardous household waste;

Construction and operation of regional storage facilities

Construction and operation of a physical-chemical treatment plant

Construction and operation of one incinerator and/or the establishment of a system of energy recovery from hazardous waste derived fuels (RDF);

Construction and operation of one hazardous waste landfill or the establishment of corre-sponding cells within other landfills and

Establishment of a management system (collection, storage, treatment, recycling and disposal) for specific waste streams, like used oils, WEEE, ELV, batteries and accumulators, medical waste, PCB and other POP waste.

This chapter shall estimate investment and operational costs of the construction and operation of such facilities mentioned above (chapter 7.2). The analysis has been implemented at incremental basis, identifying systems, plants and equipment that will be needed in future in addition to already existing (few) waste management systems that meet the legal requirements. The costs were esti-mated in EUROs, in permanent prices from 2009. Serbian prices have been adaptet to the ex-change rate of 1 Euro is 122 RSD (2016). To have a rough idea of present operational costs for hazardous waste management, and to com-pare in the following chapter with operational cost for municipal waste, German operational costs in one of the Federal States (Saxony-Anhalt, 2,23 Mio inhabitants) are given below The total costs for 2014 of 154.43 Mio. € correspond to specific costs of approximately 69 € per resident which are covered by fees that the households have to pay. The variety of waste man-agement systems in the municipalities and regions does not allow a serious comparison of the costs between them.So all costs can only be displayed totally for Saxony-Anhalt.

Table 28: Costs of municipality waste management in Saxony-Anhalt in €/inhabitant.

Area 2012 2013 2014 collection/transport 30 33 30 collecting points 3 3,5 3,5 biological treatment 2,8 2,6 4,5 mech.-biol. Treatment 2,3 2,8 4,3 thermal treatment 15,8 15,7 14,7 pre-treatment/recycling 2,6 2,6 2,5 Landfill 2,3 3,3 1,3 Administration 6,8 6,4 7,9 Total 67 70 69

The percentage of contribution to total costs is shown in the following Table. According to this, the costs for collection/transport represent 44 % and the costs for thermal treatment 21 % of the total costs.


Table 29: Rate of costs for municipality waste management activities (%).

Collection and transport 44 Thermal treatment 21 Administration 11 Biological treatment 7 Mechanical-biological treatment 6 Recycling, reuse 5 Pre-treatment, recovery 4 Landfilling 2

7.3.1 Estimated investment and operational costs for the hazardous waste management infrastructure

Components of operational costs for hazardous waste management are as follows: Administrative costs and laboratory cost for the declaration of hazardous waste and determi-

nation of the environmentally sound disposal option

Management fees from treatment plant operators and/or competent authorities for the admin-istration of such declarations and for accompaning papers necessary for hazardous waste evacuation

Waste packaging material costs (drums, canisters, pallets, big bags, IBC-containers etc.)

Handling costs at the waste disposal facility (integrated into the price of evacuation)

Waste transportation costs

Waste disposal costs

Waste declaration in terms of prove of its hazardous characteristics has its price. Before such waste takes its way to disposal facilities, generator and operator must agree about the correct treatment of such waste. This is necessary additionally to the prove of compliance between the EWC code of generated waste and the list of EWC codes permitted in this facility. Type and num-ber of compounds to be analyzed in advance depend on the type of treatment chosen and (usually) from the permit of the facility. Costs amount to approximately 350 to 500 € per analysis. Administrative costs for the control of such declarations and for the control of accompanying pa-pers additionally can amount up to 150 to 200 € per declaration.

7.3.1.1 Estimated investment and operational costs for the collection infrastructure of hazardous waste

Investment costs Collection costs consist of costs for staff, sites and containments. Costs for staff and sites have to be determined in each single case separately. Prices for containments are as follows: One way containments (lost recipients) cost from 10 € (plastic barrels) and 12 € (big bags) up to

25 € (steel drums)

Returnable IBC containments (450 – 1000 l) cost 40 € per month and bulk containers (7-12 m³) with a cover cost 25 to 30 € per month.

Apart from such investments for containments suitable for liquid or pasty hazardous waste types, there are no important additional investments necessary for hazardous waste collection infrastruc-ture: There are sufficient companies in Serbia with corresponding permits and basic equipment to take over such additional tasks. Equipment will be adjusted step by step with increasing demand and revenues.


Operational costs Transportation costs (including uploading, unloading and return) are as follows: Solid bulk semitrailer truck, 25 t load: 650 € per day

Solid waste bulk tipping container truck, 6 t load is 0,2 € per ton and km

Liquid waste suction tanker , 8 t load is also 0,2 € per ton and km

Platform truck with pellets, 5 t load is 0,25 € per ton and km

Example: Collection of 4 pallets with 16 plastic drums of 120 l each, filled with 60 kg of hazardous waste amounts to packaging costs of approximately 300 € and transport costs for 4 tons of haz-ardous waste and distance of 100 km amount to 100 €.

The following table presents an example of prices by a german waste collection and transport company.

Table 30: An example of prices asked by a german waste collection and transport company.

Soil Open or closed con-tainer

5, 7, 10 m³ 16 €/t rental fee + 75 €/unit

C&D waste uncontami-nated

Open or closed con-tainer


Mixed C&D Waste Open or closed con-tainer


Asbest waste Open or closed con-tainer


Bulk waste Open or closed con-tainer


Source: http://www.abfall-portal.de/bestellung/containerauswahl/kreis/tuebingen.html

Another example of transport unit costs used in hazardous waste generating industry in France, expressed as rental costs for containments provided by collection operators are as follows (source : ADEME (2013)):

Table 31: An example of transport unit costs used in hazardous waste generating industry in France.

Material Tariffs before tax

container 30 m3 60 à 90 €/month

container 10 m3 50 à 80 €/ month

container 15 m3 covered 90 €/ month or even more

Compacting container 30 m3

+ Equipment for leaving container

500 à 600 €/ month + 100 €/ month

Bailing press 400 à 500 €/ month

Barrels 13 à 20 €/barrel

Waste bin 1 m³ on wheels 12 à 15 €/ month

Source: http://www.ademe.fr/entreprises-monde-agricole/reduire-impacts/reduire-cout-dechets/couts-gestion In the following, an example of operational cost calculation for a hazardous waste transport in Mo-rocco (planning 2000) is given.


Table 32: An example of operational cost calculation for a hazardous waste transport in Morocco.

Collection and packaging costs 10 – 20 €/ton Transport costs (100 km) in simple trucks 20 €/tonTransport costs (100 km) in suction tank trucks 30 - 40 €/tonTransport costs (100 km) for clinical waste (truck with cooling unit) 50 €/ton

7.3.1.2 Estimated investment and operational costs for hazardous waste storage facilities

Investment costs Investment costs for storage and transfer facilities are relatively modest. Costs are composed of price of land, infrastructure installations (water, electricity and fence), a weighing bridge, laboratory, administration building and – last but not least – storage buildings and storage equipment. State-of-the-art facilities are equipped with fire protection and extinction systems and explosion resistant compartments. Underground must be sealed. A safeguarding area for unforeseen events should be integrated. All this amounts to costs of 3 to 6 Mio € for a small scale store and 10 – 15 Mio € for a large scale storage facility.. In the following, an example of investment cost calculation for a hazardous waste storage facility (4.000 tons per year) in Morocco which was integrated into a central treatment and disposal facili-ty (CNEDS planning 2008) is given.

Table 33: an example of investment cost calculation for a hazardous waste storage facility in Morocco.

Description Total costs

Terrain 5.100 €

Civil engineering 562.000 €

Equipment 18.400 €

Investment costs for buildings, ser-vice station and laboratory

410.000 €

base costs + physical risk 996.000 €

Technical assistance 49.000 €

Total general costs 1,045 Mio €

Financial risk uplift (20%) 209.000 €

Total costs 1,254 Mio €

Base costs + physical risk = terrain + civil engi-neering + equipments

General total costs = Base costs + physical risk uplift + technical as-sistance

Total costs = general total costs + financial risk up-lift


Necessary investment in Serbia Apart from such investments for adaption of existing storage facilities to State-of-the-Art technical equipment, there are no important additional investments necessary for hazardous waste storage in a short term. Generally spoken, intermediate storage capacities in Serbia should be connected with correspond-ing treatment capacities and therefore integrated into State-of-the-Art treatment facilities. So far, additional medium term investments in hazardous waste storage capacities in Serbia are part of the overall investments in treatment infrastructure. This is true for the waste management sector of end-of-life product dismantling facilities, for the sector of physical-chemical treatment facilities (in-cluding waste oil treatment) and for all other hazardous waste disposal facilities needed (like land-filling capacities and incineration capacities). Storage capacity will therefore develop step by step with increasing capacity of hazardous waste treatment facilities.

Operational costs Handling costs at such storage and transfer units (if integrated into larger treatment facilities or not) are as follows:

Service rate for weighing, acceptance/entrance control and waste identification (comparison of waste declared and arriving waste load), taking samples if necessary and screening laboratory test amounts to 40 € per transport unit

Unloading of pallets and/or drums is 15 € per transport unit

Emptying of solid waste bulk containers up to 1.000 l (IBC) is 30 € per transport unit

Emptying of liquid waste tank container up to 1.000 l (IBC) is 80 € per unit

Truck/tank cleaning and evacuation of cleaning water in adjacent Physical-Chemical Treatment plant (PCT) is 30 € and

Truck/tank cleaning and evacuation of cleaning water in incineration is 80 €.

In the following, an example of operational cost calculation for a hazardous waste storage facility (4.000 tons per year) in Morocco which was integrated into a central treatment and disposal facili-ty (CNEDS planning 2008) is given (in €).

Table 34: An example of operational cost calculation for a hazardous waste storage facility in Morocco.

Consumables Maintenance and repair Monitoring and administration staff

2.200 24.500 9.700 15.500 4,3% 47,2% 18,7% 29,9%

51.900 Total operational costs in 2020 14,43 €/t in 2020

7.3.1.3 Estimated investment and operational costs for physical-chemical treatment plants

Investment costs The investment costs depend on the technology applied for waste treatment. The choice of a site, in addition to the plant size, can significantly influence investment costs. The investment costs for physical-chemical treatment depend on the complexity of necessary treatment which depends on the complexity and variety of waste to be treated.


The choice and design of the process technology depend as well: on the residues that are expected in order to find appropriate solutions for the resulting residues

and on the necessary quality of the waste water to be lead into the sewer system.

Like in other cases, the choice of the site, in addition to the plant size, will significantly influence in-vestment costs and - through the expected return – indirectly influence the operational costs. Con-siderable reduction of the operational costs can be achieved by the right combination and the right follow-up of process steps and through returns from secondary raw materials extracted from the treated waste (solvents, oil, salts, acids etc). Fa. Zimmermann, Gütersloh an operator with several PCT plants in Germany (treatment capacity of 160.000 tons) recently planned a new PCT installation in southern Germany (on the site of chemical industry BASF in Grenzach-Wyhlen) fr approximately 5 Mio €. The plants intend to treat liquid and pasty hazardous waste from 160 firms mainly from chemical industry with a capacity of 60.000 tons and to operate a solid waste treatment plant (for RDF) with a capacity of 80.000 tons per year. Total throughput of the facility will be 130.000 tons per year. (source:http://www.die-glocke.de/lokalnachrichten/kreisguetersloh/guetersloh/Entsorger-Zimmermann-baut-bei-BASF-22d593c2-e3d5-47d4-85e2-fc7c53f5d368-ds) In the following, an example of investment cost calculation for a hazardous waste treatment facility in Morocco which was integrated into a central treatment and disposal facility (CNEDS planning 2008) is given.

Table 35: Investment costs for physical-chemical treatment facility, inorganic part (17.000 – 20.000 tons per

year):


Terrain 0 €


Equipment 6,20 Mio €


2,01 Mio €

base costs + physical risk 7,19 Mio €



Financial risk uplift (20%) 1,51 Mio €



Table 36: Investment costs for physical-chemical treatment facilty, organic part (7.000 – 8.000 tons per year):


Terrain 1.600 €




738.600 €









Another example of investment cost calculation for a hazardous waste physical-chemical treatment facility in Tunisia (construction 2007) is given here:’

Table 37: An example of investment cost calculation for a hazardous waste physical-chemical treatment

facility in Tunisia.

Total treatment capacity per year 18.000 tStabilization/solidification capacity per year 20.000 tStorage capacity per year for waste to be incinerated 1.500 tStorage capacity per year for waste to be recycled 1.000 tInvestment for process equipment (without civil engineering works) 5 Mio €Total investment cost 11,5 Mio €

A smaller regional intermediate storage and treatment facility without physical-chemical treatment, but with stabilization, pre-treatment (preparation for transport), landfilling and storage capacities amounted to approximately 3 Mio € in Tunisia. Single cost factors are presented in the following table.


Table 38: An example of costs for a smaller regional intermediate storage and treatment facility in Tunisia.

Road for access and interiour roads 260.000 Landfill and drainage bassins 830.000 Civil engineering work 540.000 Buildings 130.000

Water drainage and supply system (raw water, leachate and rain water, )

12.000

Electricity, electrical and electronical supply net 206.000 Stationary equipments (for stabilisation and pre-treatment *)

828.700 *)

Water and electricity supply 48.000 Discharge flow meter 2.000 Total costs 2,9 Mio € From this, the stabilization and pre-treatment component assumed to 828.700 €, which is about 30% of total investment. Single cost elements have been: Type of equipment for waste treatment and storage

Number Price per unit in € Total price in €

Silo for additives 2 9.500 19.000Tank for additives 2 3.500 7.000

Tank for dosage of process water

1 3.500 7.000

Mixing unit for waste and additives

1 82.000 82.000

Convevor belt for solid waste

1 9.000 9.000

Tank for dosage of reagents 1 1.800 1.800Reception container 4 2.100 8.400Storage containment 3 10.500 31.500Water pump 8 6.600 53.000Sludge pump 1 7.000 7.000

Tank for dosage of poly-electrlytes

1 3.600 3.600

Compressed air supply installation 1 18.000 18.000Conduct equipment 3 19.500 58.500Measuring equipment 1 19.500 19.500Hardware 1 4.500 4.500Software 1 9.300 9.300Storage equipment 1 24.500 24.500

Fire protection installations and equipment

1 55.500 55.500

Fire extinctors and first aid equipment

1 3.000 3.000

Forklift truck 3 8.200 24.600Scales / balance 1 87.000 87.000Service station 1 15.000 15.000Laboratory equipment 1 34.000 34.000Bureau equipment 1 20.000 20.000

Big truck for waste transport 3 61.600 185.000Small truck for waste transport

2 20.500 41.000

Total 828.700


Necessary investment in Serbia Like mentioned before, limited treatment capacities for certain hazardous waste types are availa-ble in Serbia.. Apart from necessary investments for adaption of such existing treatment facilities to State-of-the-Art technical equipment, there are important additional investments necessary for hazardous waste physical-chemical treatment in a short term. Such additional investments in hazardous waste treatment capacities in Serbia are part of the overall investments in treatment infrastructure for industrial and chemical waste from industry. This treatment capacity amounts to approximately 45.000 tons. Moreover, state-of-art treatment capaci-ties for waste oil need to be upgraded. It is estimated, thatin a range of additional 4.000 to 5.000 tons is needed on a short term. On a medium term, hazardous waste collection activities from households and commerce will bring forth additional quantities of several hundred tons of liquid and pasty hazardous waste.

Table 39: Necessary investment in Serbia.

Physical-chemical treatment capacity per year needed on a short term 45.000 tFrom this: - distillation capacity - neutralization capacity - detoxification and CPO capacity - solidification capacity

2.0005.000 – 10.000

20.000 – 30.0008.000

Additional state-of-art waste oil treatment capacity per year, on a short term

5.000 t

Storage capacity per year for waste to be incinerated or re-used as fuel 5.000 tStorage capacity per year for waste to be exported 1.000 tInvestment for treatment facility 12 - 20 Mio €Investment for storage facility 3 - 5 Mio €Total investment cost 15 - 25 Mio €

Considering the above mentioned factors the investment costs for a new physical-chemical treat-ment plant in Serbia are in a range of about 15 to 25 Mio € (depending on the site and the size of the plant). Operational costs The choice and design of the process technology predominantly affect the treatment costs; the treatment costs, again, depend on the expected revenue of the investment costs and the opera-tional costs. The investment costs and the expected revenue of investment costs usually are the most important driver when determining treatment costs per ton of hazardous waste. The operational costs of the physical-chemical treatment of hazardous waste depend- besides the expected revenue of investment cost - essentially on the following factors: waste composition in terms of necessary steps of treatment, i.e. process costs

process and plant engineering, influencing the process costs as well

energy consumption and chemicals demand for processing and

costs for disposal (landfilling or incineration, export) of residue.

Considerable reductions of the costs can be achieved by ensuring economically efficient year-round heat utilization.


Three different basic prices should be established: 1. Unit price for inorganic waste requiring lower expenditures for treatment: This is normal acids

and bases , thin sludge, paints and varnishes, waste waters and washing waters. They need neutralization, flocculation and precipitation/filtration only.

2. Unit price for (liquid and pasty) organic waste containing oil-water mixes, oil-water separation content, waste from grits and sand chambers. This waste needs separation of floating oil phase first (skimming) and separation of solids (decanter). After this, flocculation and precipi-tation are common.

3. Unit price for waste predominantly inorganic which requires high expenditure treatment; this waste contains concentrated acids needing dilution before neutralization; sulphuric and phos-phoric acids that produce - during neutralization with lime - high quantities of sludge; waste from complex chemical agents, waste with cyanides, chromates and nitrites which often re-quire an additional time consuming treatment in particular oxidation and reduction reactions.

Within these groups prices can further be differing dependent of the pH, oil content or other criteria. The price system should be logical and systematical in order to give generators the chance to search for alternatives i.e. by proper pre-treatment steps before evacuating the waste. An example of the structure of prices for physical-chemical treatment of inorganic contaminated waste water surcharges comes from a facility in Germany (HIM 2002) is given in the following.. Meanwhile the market prices have changed a lot, but the relation of prices still is valid. Table 40: An example of the structure of prices for physical-chemical treatment of inorganic contaminated

waste water surcharges (Germany).

Specific prices for surcharges of sludge por-tion after neutralization (in €/ton)

Surcharges for detoxificationof Cyanide, Chromate and Nitrate (in €/ton)

<10% 60 < 100 mg/l 25<25% 130 <500 mg/l 40<50% 200 <1 g/l 70<75% 280 <10 g/l 120>75% 370

Surcharges for treatment of organic solvents incl. halogenated (in €/ton)

Surcharges of inorganic waste water pH (in €/ton)

1 mg/l 30 pH 6-9 0 10 mg/l 40 pH 2-6 and 9-12 75 20 mg/l 90 Acids and bases <5% 9550 – 100 mg/l 170 Acids and bases <

29% 160

Acids and bases <30% 200 Usual treatment costs in PCT facilities in Europe range between 60 and 450 €/ton. Treatment costs of under 100 € per ton of hazardous waste can be achieved even with small plants (approx-imately 10,000 to 25,000 tons per year) if above mentioned conditions are favorable. Table 41: Composition of specific costs for physical-chemical treatment of hazardous waste.

Composition of specific costs for physical-chemical treatment of hazardous waste (%) Capital 30 - 40Manpower 10 - 15Service and maintenance 5 - 15Laboratory 5 - 7Residual disposal 10 - 15Chemicals 3 - 5Administration and others 10 - 15


An example of operational cost calculation for a hazardous waste physical-chemical treatment facil-ity in Morocco which was integrated into a central treatment and disposal facility (CNEDS plan-ning 2008) is given in the following (in €). Table 42: Operational costs for physical-chemical treatment facility, organic part (7.000 – 8.000 tons per year,

in €).


108.000 94.600 17.400 27.900 43,6% 38,1% 7,0% 11,3%


Table 43: Operational costs for Physical-chemical treatment facility, inorganic part (17.000 – 20.000 tons per

year, in €).


235.600 178.400 47.600 63.500 44,9% 34,0% 9,1% 12,1%


7.3.1.4 Estimated investment and operational costs for the incineration and the energetic re-use of hazardous waste as fuel

Investment costs Due to the complexity of exhaust gas treatment the investment costs for incinerators are extraordi-narily high and - through the expected return – the biggest factor when determining treatment costs per ton of hazardous waste. The choice and design of the process technology - grit firing or rotary kiln firing - affect the treatment costs less. Like in other cases, the choice of a site, in addition to the plant size, will significantly influence in-vestment costs as well and - through the expected return – will influence the operational costs, too. Considerable reductions of the operational costs can be achieved by sufficient size of the capacity of the plant and ensuring returns from efficient year-round heat utilization of waste energy. In April 2016 China Everbright International Limited Group announced an investment agreement for the Kunshan Industrial Hazardous Waste Incineration Project with the People's Government of Zhangpu Town, Kunshan City of Jiangsu Province. This hazardous waste Incineration project is designed with an annual incineration processing capacity of 30,000 tons and will be constructed in two phases. Phase I of the project has an annual hazardous waste processing capacity of 20,000 tons with a total investment of approximately RMB 253 million (34,2 Mio Euro). The project will de-ploy the newly imported hazardous waste countercurrent rotary kiln technology from Belgian com-pany BIC and its gas emissions will fully comply with the Euro 2000 Standard. (source:http://www.ebchinaintl.com/en/investors/press_each.php?id=p160428) Another example of investment costs and specific investments costs for hazardous waste incinera-tion are given below.


Table 44: An example of investment costs and specific investments costs for hazardous waste incineration.

Turkey (2007) capacity hazardous waste , 100.000 t/abuffer capacity 5 daysThermal capacity 2 x 20 MWth

Waste type: solid bulky waste, drums, liquids sludge special charges Total investment 50 Mio €average investment costs 500 €/t year

For the incineration facility Biebesheim HIM Germany (construction 1988-1999) the differentiation of investment costs can be given (in Mio €). Table 45: An example: investment costs For the incineration facility Biebesheim HIM Germany.

Waste type: solid bulky waste, drums, liquids sludge special charges Incineration capacity for hazardous waste : 100.000 t/a buffer capacity: 5 days Bunker 6 Spray dryer 3Rotary kiln + second-ary combustion chamber 13

Electrostatic filter 2

Flue gas scrubber 10

boiler 8 Bag house filter 18Tank farm 11 Slack and emergency

outlet 4Drum storage 4infrastructure 9 El.power supply 12Total investment 100 Mio €average investment costs 1.000 €/t year

Incineration in cement industry The following cost examples are relevant for Serbia because – due to European funds applied -requirements have been adopted which are similar to EU wide state-of–the-art technologies. An example of investment cost calculation for the extension of a cement plant for hazardous waste in-cineration in Tunisia (planning from 2009) is given below. Table 46: An example of investment cost calculation for the extension of a cement plant for hazardous waste

incineration in Tunisia.

Adaption of rotary kiln technology for all kind of hazardous waste to be incinerated ( solid, pasty, liquid in bulk or in drum + Interim storage for bulky waste for minimum 5 days + adaption of gaz treatment unit to European standards + planning costs) Total capacity for waste incineration per year 30.000 tonsTotal investment cost 30 Mio € In this context, the investment costs for the equipment to inject different types of waste into the kiln have been calculated as follows:

Tipple damper for solid waste and tires via pre-calcinator: 200.000 – 250.000 € Storage vessels and injection unit for liquid waste via main burner: 1 – 1,2 Mio € Storage / transport unit and jnjection unit for solid waste via pre-calcinator: 1,7 – 2,7 Mio €

Another example of investment cost calculation for the preparation of secondary fuel for cement kilns in Morocco which was integrated into a central treatment and disposal facility (CNEDS plan-ning 2008) is given below.


Table 47: An example of investment cost calculation for the preparation of secondary fuel for cement kilns in

Morocco.

Investment costs for National Treatment and Disposal Center CNEDS in Morocco (2008) in €

Equipment Pro-

cess Civil Engineering Total

Platform solid alternative fuel preparation 3.818.880 546.000 4.364.880 Platform liquid alternative fuel preparation 334.400 17.500 351.900 Total 4.716.780

*) „Costs might vary +/- 20% and comprise planning, construction and preparation for operation costs » In Port-la-Nouvelle Plant in France (Lafarge) an investment of 2,5 Moi € has been realized in July 2007 to introduce a processing unit for shredded solid waste such as tires. The Cauldon plant in the UK from LAFARGE had indicated an investment for the use of scrap tires as an alternative to petcoke and coal in the range of 2,2 Mio € (2006). Over the last ten years, it has used around two million tires a year, allowing an annual saving of 24 000 tons of fossil fuel (source: Lafarge.com)

New fuel dosing system for liquid waste in St.Marys Cement Plant/Canada amounted to an invest-ment of Can$ 1.9 Mio , equivalent to 1,320 Mio € (source www.iipnetwork.org). Necessary investment in Serbia Considering the above mentioned factors the investment costs of a new waste incineration plant in Serbia are in a range of about 50 to 80 Mio € (mostly dependent on the size of the plant). Cement industry can start from much lower investment costs, because more than half of the necessary technical equipment exists already. Limited capacity of energetic re-use of waste oil in Serbian cement industry in the range of 15.000 tons per year is available at once; additional capacities of approximately 30.000 tons per year can be made available in near future. Meanwhile export of industrial organic hazardous waste, of or-ganic dismantling residues and of organic residues from physical-chemical treatment will continue. All three cement plants are ready to expand their capacity for thermal treatment of waste oils to the extent that total amount of waste oil generated in Serbia could be treated in this way. Investments for increasing capacity of cement industry for the thermal treatment of waste oils to a level of 45,000 tons per year, would be between 4,5 and 6 million Mio €. Investment for a wider range of hazardous waste types would be between 15 and 30 Mio € in total. But hazardous waste collection activities from households and commerce will bring forth additional quantities of several hundred tons of liquid and pasty organic hazardous waste which needs incin-eration; physical-chemical treatment facilities will also generate several thousand tons of organic residues that need incineration; and finally dismantling and recycling facilities for end-of-life-products (ELV, WEEE, transformers etc.) produce organic residues in the range of several thou-sand tons per year that need thermal treatment. Important additional investments in new incineration facilities for mixed organic hazardous waste in the range of 30.000 to 32.000 tonnes per year are therefore necessary in a medium term and de-pend on the time schedule of progressive close-down of organic waste landfilling practice in Serbia. Such new and significant investment in hazardous waste incineration capacities is an essential part of the establishment of an integrated hazardous waste management concept in Serbia. Without such incineration capacity other disposal options (e.g. physical-chemical treatment) and recycling activities (e.g. WEEE dismantling) are hindered or blocked.


It is particularly the manufacturing, pharmaceutical and chemical industry that will profit from such investment. Therefore new incineration capacities could be located within or nearby industrial hotspots where such incineration capacities are needed. It corresponds to MS experience that such facilities easily can be docked to industrial plants where necessary experience in hazardous sub-stances’ handling, sufficient space and parts of the equipment are available. Necessary investment for providing such additional capacities for incineration of industrial residues is much lower than to plan and construct such capacities outside. Table 48: Necessary investments for incineration in Serbia.

Hazardous waste incineration capacity per year needed on a medium term

18.500 – 25.000 t

From this: - organic chemical waste from household collection - hazardous organic residues from physical-chemical treatment - hazardous organic residues from sorting and dismanteling facilities - hazardous waste from Health Care Institutions

4.000 – 8.0002.000

7.500 – 10.0005.000

Additional waste oil re-use capacity per year, in cement kilns 15.000 – 45.000 tStorage capacity per year for waste to be exported (POP waste etc.) 1.000 tInvestment for incineration facility 50 - 80 Mio €Investment in cement industry 15 – 30 Mio € Investment for storage facility 1,5 - 3 Mio €Total investment cost 66,5 - 113 Mio €

Operational costs The costs of the incineration of waste depend essentially on the following site specific features: Waste composition, in terms of necessary pre-treatment steps and expense for complete de-

struction of hazardous substances in the waste (process costs)

Process and plant engineering,

Thermal output from the incineration and resulting returns for heat and energy re-use

Cost for the final disposal of residue or revenues from recycling (e.g. from ferrous metals) re-spectively.

Following costs are integrated into the treatment costs: capital costs (financing of investment)

return of own capital

personal costs (up to 100 persons)

variable costs (disposal of residues, chemicals)

fixed operational costs (personal, energy, capital costs, laboratory, maintenance, insurance)

administrative costs.

Operational cost in terms of specific costs (per waste type and per ton) and market margin (profit) decide about the disposal sales price. An example of cost calculation of a hazardous waste incinerator in Germany is given below (in Mio € per year).


Table 49: An example of cost calculation of a hazardous waste incinerator in Germany.

Capital (fixed costs) 4,5Manpower (fixed costs) 5Service and maintenance (fixed costs) 1,5Laboratory (fixed costs) 0,3Residual disposal (variable costs) 2Exhaust gas treatment (variable costs) 1,4Administration and others (fixed costs) 1,5Return on own capital (fixed costs) 2Total operational costs 18,2Average disposal price (100.00 t throughput) 182 €/ton Usual treatment costs for hazardous waste incineration in Europe range between 100 and 500 €/ton. Laboratory chemicals, pesticides and PCB might range up to 2.500 €/ton. Average treat-ment costs are around 300 €/t. Treatment costs of under 300 € per ton of hazardous waste can be achieved even with small plants (approximately 10,000 to 25,000 tons per year) if above mentioned conditions are favorable. Overcapacities in Europe are cutting continuously the disposal prices of incineration. Examples for waste specific incineration costs can be given from 2 Turkish hazardous waste incin-eration facilities (2009) in in € per ton: Table 50: Examples for waste specific incineration costs (2 Turkish hazardous waste incineration facilities).

Liquid waste with sludge <10% Incinerator 1 Incinerator 2 Calorific value >18 MJ/kg 190Calorific value > 10 MJ/kg 400Calorific value < 10 MJ/kg 460Pasty waste with sludge 25-75% Calorific value >18 MJ/kg 350 310Calorific value > 10 MJ/kg 450 400Calorific value < 10 MJ/kg 500 490Solid waste with sludge > 75% Calorific value >18 MJ/kg 600 570Calorific value > 10 MJ/kg 780 680Calorific value < 10 MJ/kg 850 740 Other prices for typical chemical waste for incineration in European hazardous waste incineration plants are presented below.


Table 51: Prices for typical chemical waste for incineration in European hazardous waste incineration plants.

Type of waste Detailed description of waste Price in € per ton

without tax Solvents Waste solvents (not halogenated) 150

Waste oil emulsions : mixture of oil and water( about 10% of oil) with metal cuttings

250

Fluorescent tubes Waste fluorescent tubes 250 Paints Waste paints 380 Different liquid chemical products

chemical products like varnishes, resins and ink 380

EPOXY powder EPOXY powder 380 Dirty solid clothing wastes Waste cleaning cloth with solvents, paint and glue 380 Polyol / Isocyanate polyurethane foam 1200 Aerosols Empty aérosols cans (majority), half full and full cans 1200

Incineration in cement plants is much more economic. The costs differ - depending on the neces-sary investments – commonly between 30 and 300 €/t., while, for example, operating costs of thermal treatment of hazardous agrochemical and industrial packaging waste is as much as 400 euros per tonne. Another example of operational costs for different steps of hazardous waste management are giv-en below (source: ADEME (2013).


Table 52: An example of operational costs for different steps of hazardous waste management.

Type of treatment Treatment tariffs

Industrial waste storage (non-hazardous) 60 à 100 €/t

Commercial waste incineration (non-hazardous)

70 à 120 €/t

Hazardous waste incineration

from 0 (high calorific liquid wastes) to 1 000 €/ton or even more depending on waste : Exemples :

aqueous organic liquids : 100 €/t. aérosols : 800 à 1 000 €/t.

Energy recovery in Cement Industry 0 price for high calorific liquids otherwise, from 40 to 150 €/t

CPT (aqueous liquids) 70 à 200 €/t

Hazardous waste landfilling 120 à 240 €/t or even more if stabilisation is neces-sary

Source: http://www.ademe.fr/entreprises-monde-agricole/reduire-impacts/reduire-cout-dechets/couts-gestion) In Germany, cement industry asks 0 – 15 €/t for incineration of high-calorific solid waste-derived-fuels from industry (more homogenous) and 8 – 30 € for such fuels derived from household waste. Lower qualities cost 50 – 70€/t (source : German Federal Agency of Environment, Best Practice Paper WT/I-01_ICC).

7.3.1.5 Estimated investment and operational costs for landfills

Investment costs The investment costs of a hazardous waste landfill depend – due to its large surface needed – es-sentially on the following factors: site installation costs and space needed

state-of-the-art technology needed for sealing and drainage of leachate and gas;

pre-treatment technology for leachate and disposal options for leachate and gas

monitoring systems for environmental security and operational safety.

The investment costs for hazardous landfills are - due to the complexity of the sealing and draining technologies needed - the biggest factor when determining disposal costs per ton of hazardous waste to be landfilled. The choice and design of the landfilling technology (machinery, staff and control) affect the landfilling costs less. The choice and the size of the site will significantly influence the investment costs, too and - through the expected return - also the operational costs. Considerable reductions of the operational costs can be achieved by sufficient volume and capacity of the plant. Measures for reducing costs of the capture and treatment of resulting effluents (re-infiltration of leachate) and gases can be decisive for disposal sales prices: In the context of former organic landfills it has been noticed that the revenues from electricity production and from Carbon trade based on the achieved certified emission reductions (CER in CO2äqu / t of waste) could significant-ly reduce investment and operational costs of landfills. An example of investment cost calculation for a hazardous waste landfill in Tunesia (construction 2005-2007) is given below.


Table 53: An example of investment cost calculation for a hazardous waste landfill in Tunesia.

Waste to be landfilled per year 25.000 t/aTotal waste capacity (20 years of operation) 500.000 tTotal waste volume 335.000 m³Total landfill surface 33.000 m²Surface of leachate pond (evaporation pond) 5.000 m²Total investment cost without final surface sealing and re-cultivation 5 Mio €Final surface sealing and re-cultivation (after 23 years), prices of 2005 2,5 Mio €

Another example of investment cost calculation for the pre-treatment before landfilling (8.000 – 9.000 tons per year stabilization) facility and the landfilling plant (36.000 – 40.000 tons per year) in Morocco which was integrated into a central treatment and disposal facility (CNEDS planning 2008) is given in the following. Table 54: An example of investment cost calculation for the pre-treatment before landfilling.

Investment costs for a stabilisation facility:


Terrain 1.400 €


Equipment 818.400 €


851.300 €






Investment costs for a hazardous waste landfill facility:


Terrain 270.000 €

Civil engineering 6.73 Mio €



6,06 Mio €


Technical assistance 2,035 Mio €


Financial risk uplift (20%) 3,498 Mio €






Necessary investment in Serbia Considering the above mentioned factors the investment costs of a new hazardous waste landfill in Serbia are in a range of about 5 to 10 Mio € (mostly dependent on the size of the plant). Limited capacity for landfilling of hazardous waste in Serbian municipal landfills in the range of 15.000 tons per year can be made available in near future, if operators are willing to engage and invest in such landfilling cells, which are separated from the municipal landfilling cells. Taking into account the low technical standard of such landfills in operation, certain investments for adaption of existing facilities to State-of-the-Art technical standard are necessary. Meanwhile export of indus-trial inorganic hazardous waste, of inorganic dismantling residues and of inorganic residues from physical-chemical treatment will continue. Hazardous waste collection activities from construction sector, will bring forth additional quantities of several thousand tons of mineral hazardous waste (tars, contaminated soils, asbestos) which needs landfilling; physical-chemical treatment facilities will also generate several thousand tons of mineral residues that need landfilling; incineration will generate filter ashes from exhaust gas treatment that need hazardous waste landfilling and finally dismantling and recycling facilities for end-of-life-products produce residues(metals, glass etc.) in the range of several thousand tons per year that need landfilling. Important additional investments in new hazardous waste landfilling capacities for mixed inorganic hazardous waste in the range of 500.000 to 1 Mio tons or around 1 Mio m³ total volume are there-fore necessary in a medium term and depend on the time schedule of progressive close-down of existing low technology landfilling (or dumping) practice in Serbia. Such new and significant in-vestment in hazardous waste landfilling capacities is an essential part of the establishment of an in-tegrated hazardous waste management concept in Serbia. Without such capacity other disposal options (e.g. physical-chemical treatment), incineration and recycling activities (e.g. WEEE disman-tling) are hindered or blocked. It is – once more –the manufacturing and chemical industry that will particularly profit from such in-vestment. Therefore new landfilling capacities could also be located within or nearby industrial hotspots where such landfilling capacities are needed. It corresponds to MS experience that such landfilling capacities might be docked to industrial facilities where necessary experience in hazard-ous substances’ handling, sufficient space and parts of the equipment are available. Investments for providing such additional capacities for landfilling within an industrial area normally are lower and easier to realize than to follow a greenfield strategy in planning such capacities .


Table 55: Necessary investments for Landfilling in Serbia

Landfilling capacity per year needed on a medium term 50.000 - 70.000 tFrom this: - contaminated soils - residues from physical-chemicl treatment - residues from dismanteling facilities (ELV, WEEE) - hazardous waste from thermal processes (EWC Gr 10.02) - others

3.000 - 5.0007.000 – 10.000

2.000 – 5.00010.000 - 12.00028.000 – 38.000

Storage capacity per year for waste to be exported 1.000 tInvestment for landfilling facility 5 - 10 Mio €Investment for storage facility 1,5 Mio €Total investment cost 6,5 – 11.5 Mio €

Operational costs Operational costs of hazardous waste landfills depend on the following factors and within a range mentioned below: Table 56: Composition of specific costs for landfilling of hazardous waste.

Composition of specific costs for landfilling of hazardous waste (%) Capital 35Manpower 5Service and maintenance, control 20Laboratory 5Machinery 5Effluents and gas evacuation 25Administration and others 5 Usual disposal costs for hazardous waste landfills in Europe range between 50 and 140 €/t. Op-erational costs of under 100 € per ton of hazardous waste can be achieved even with small plants (approximately 10,000 to 25,000 tons per year) if above mentioned conditions are favourable. If solidification is necessary before landfilling the costs increase by 30 to 50 €/ton. Examples for disposal costs in a Turkish hazardous waste landfill are given below (in € per ton). Table 57: Examples for disposal costs in a Turkish hazardous waste landfill.

Hazardous mineral waste 115 Inert industrial waste 75 Industrial non-hazardous waste mixed with municipal waste 85 Industrial waste similar to municipal waste 20 Another example of operational cost calculation for a hazardous waste pre-treatment facility (stabi-lization) before landfilling and a landfilling plant in Morocco which was integrated into a central treatment and disposal facility (CNEDS planning 2008) might be given here (in €): Table 58: An example of operational costs for a stabilisation facility (8.000 – 9.000 tons per year, in €) in Ma-

rocco.


162.600 42.200 20.300 28.000 64,2% 16,7% 8,0% 11,1%



Table 59: An example of operational costs for a landfilling facility (36.000 – 40.000 tons per year, in €) in Ma-

rocco.


411.000 222.800 100.500 116.400 48,3% 26,2% 11,8% 13,7%


Special attention must be paid to the fact that costs of landfilling must include the long-term costs for the after-closure care phase. These costs must be covered by the specific landfill fee charged to the generator. Such costs depend on the period of such after care prescribed in the permit. Thirty years is the minimum period under the EU Landfill Directive and also according to the Serbian Waste Management Act. Further costs need to be taken into account when authorities are fixing the financial security in the permit. The assessment of a security is a prerequisite for issuing a landfill permit in Serbia. Such fi-nancial security might influence the investment and operational costs of the landfill significantly.

7.3.1.6 Estimated investment costs for a central treatment and disposal facility for hazardous waste

It is evident, that the concentration of all these facilities at one single site can diminish the invest-ment costs of the overall and integrated hazardous waste management system in Serbia. As an example of the investment costs for such a center might be taken from the concept of the CNEDS in Morocco, where following investment costs have been calculated.


Table 60: An example of the investment costs for a center for treatment and disposal of hazardous waste

Investment costs for National Treatment and Disposal Center CNEDS in Morocco (2008) in €

General

equipment Process

equipment Civil Engi-

neering Total

Platform solid alternative fuel preparation

3.818.880 546.000 4.364.880

Platform liquid alternative fuel preparation

334.400 17.500 351.900

Stabilization (8.000 – 9.000 t/a) 818.380 31.500 849.880 Physical Chemical Treatment in-organic PCTi, 17.000 – 20.000 t/a

2.808.950 445.000 3.063.220

Physical Chemical Treatment- organic PCTo 7.000 – 8.000 t/a

2.849.720 213.500 1.638.360

Storage area for drums (2.000 t/a)

18.400 513.510 531.910

Storage area for containers (2.000 t/a)

48.260 48.260

Social building 60.000 437.580 497.580 Work and service station 133.400 342.340 475.740 Administrative building 115.000 643.500 758.500 Laboratory 1.113.200 437.580 1.550.780 Reception et monitoring area 80.500 9.650 90.150 Roads within facility area, fences, gate

46.000 2.685.600 2.731.600

Mobile equipment 1.960.000 1.960.000 Subtotal 18.913,000 Landfill (36.000 – 40.000 t/a) 2.400.000 6.060.000 6.730.000 15.190.000Total 34.103.000

*) „Costs might vary +/- 20% and comprise planning, construction and preparation for operation costs » Total costs – incineration unit not included - amounted to approximately 34 Mio €. Another example of cost estimation for a central hazardous waste management solution is the fol-lowing study on three alternatives for Santa Fe de Bogota / Colombia, realized by a German Con-sulting Group in the year 2000:(Source: Proyecto PNUD/CO/96/023 Diagnóstico Ambiental de Al-ternativas para la ubicación de Instalaciones para la disposición final de sustancias tóxicas y peligrosas inertizadas en Bogotá, Unión temporal: HIMTECH / ERM-LAHMEYER / AMBIENTAL CONSULTORES, RESUMEN EJECUTIVO december 2000)


Table 61: An example of cost estimation for a central hazardous waste management solution.

Alternative 1

Facility type

HW Landfill (cell with-in munic-ipal land-fill)

Stabilization facility

Total

Capacity 5.000 – 13.000 t/a

10.000 – 25.000 t/a

15.000 – 28.000

Investment costs

2,4 Mio €

Operational costs

1,43 – 2,51 Mio €

Specific operational costs

95 – 90 €/t

Alternative 2

Facility type HW Landfill (full size)


Waste derived fuel plant

Physical-chemical treatment plant

total

Capacity 10.000 – 15.000 t/a

10.000 – 25.000 t/a

6.000 – 15.000 t/a 6.000 – 15.000 t/a

32.000 – 70.000

Investment costs

21,5 Mio €

Operational costs

4,03 – 6,27 Mio €


126 – 90 €/t

Alternative 3

Facility type HW Landfill


Waste de-rived fuel production plant

Physical-chemical treatment plant

Incineration unit

Capacity 10.000 – 15.000 t/a

10.000 – 25.000 t/a

6.000 – 15.000 t/a 6.000 – 15.000 t/a

28.000 t/a

Total capa-city of site

Site 1 : 25.000 – 40.000 t/a

Site 2: 40.000 – 58.000 t/a

Investment costs

52,9 Mio €

Operational costs

11,20 – 13,44 Mio €


172 – 137 €/t

Total investment for full size Facility Park including incineration unit corresponds in this case to ap-proximately 53 Mio Euro and operational costs of 137 to 172 Euro per ton, depending on the ca-pacities installed. In the same case study the following treatment tariffs (€/t) have been reported to be cost-covering prices:


Table 62: A nexample of treatment tariffs

HW landfill 50 – 107 Stabilization 143 - 233 WDF production 116 - 152 Health care waste disinfection 215 - 304 Physical-chemical treatment 215 - 304 Incineration 330 - 493

7.3.2 Estimated investment and operational costs for specific waste stream covered by extended producer responsibility systems

7.3.2.1 Estimated investment and operational costs for hazardous C&D waste management

including asbestos waste management

As stated in the Serbian Waste Management Strategy 2010-2019 total investment costs for the sector of construction and demolition waste was estimated with 28 Mio € for the time period 2010-2014 and 32 Mio € for the time period 2015-2019 (MAEP 2010). Present state of disposal costs for asbestos containing waste Present waste management costs for mineral C&D waste can be considered very low or nearly 0 (in case of illegal dumping) or up to a few 100 RSD (1-3 €) per ton for authorized landfills. Also transport costs are low due to the large number of dump sites and the resulting short transport dis-tance. Due to this situation there is no incentive to keep hazardous and non-hazardous C&D waste separate. This situation bears risks due to potentially very high hidden costs in case of accidents and envi-ronmental incidents. These hidden costs comprise also social costs for occupational diseases and disability of workers and diseases from local residents due to exposure to hazardous substances (namely asbestos); they comprise also as well as future clean-up costs for illegal dump-sites and remediation works. Investment costs for removal, handling and disposal of asbestos waste

The following approximations concerning future investment costs of hazardous C&D waste can be given:

Investment costs for equipment The minimum investment costs for the equipment necessary to start a sanitation process (vacuum cleaner protective equipment for three persons, exhaust system, etc.), for asbestos can be esti-mated in the range of 9.000 € (data from Austria; no equipment costs for fiber measurements in-cluded). For the removal of asbestos cement only, equipment costs are about 1.500 € (vacuum cleaner class H; protective masks/clothing). In this case, the measurement of the residual fiber concentra-tion shall be done by an external accredited laboratory. However these costs will depend widely on the size of the equipment and consequently the dis-posal/clean up capacity. As long as asbestos waste is disposed off illegally at relatively low costs there will be some reluctance of the private sector to invest in the necessary infrastructure. A close monitoring of the dismantling and demolition of buildings by the authorities competent for waste management as well as of those competent for the workplace safety will be necessary to prevent il-legal disposal and increase the level of investments into suitable equipment.


Investment costs for a collection and storage system Estimating the costs of a fully equipped storage for hazardous wastes with 1.000 €/m² the addi-tional costs for a compartment for asbestos can be estimated with 10.000 to 15.000 € per storage (based on experiences in Austria). This storage should preferably be integrated into the regional storage and treatment facilities for C&D waste. This implies transport by local C&D transport and recycling firms which often are part of local construction firms. The costs of a fully equipped lorry suitable for asbestos waste can be estimated in the range of 150.000 to € 200.000 €. There are no specific costs for the collection of such asbestos containing wastes. Investment costs for landfilling In the case of a modern landfill in accordance with the Regulation on Disposal of Waste to Landfills no additional cost are assumed. To handle asbestos wastes and asbestos containing wastes in a save manner no additional equipment is necessary. The treatment in accordance with best practice is a mere managing issue. The input control and the on-site verification personnel have to be trained specifically, however in accordance with the Regulation trained personnel is a pre-requisite for the save operation of the landfill in any case so no additional cost can be assigned to the ac-ceptance of asbestos containing wastes. However since asbestos wastes are landfilled in a specific compartment and designated area of the landfill the investment cost in building the landfill site might be slightly higher because the timeframe for the return of investment of that specific compartment might be much longer than for other compartments. Based on information from Western Europe Countries the investment cost for a landfill for non-hazardous wastes are in the range of 10 €/m³ to 25 €/m³. Operational costs for removal, handling and disposal of asbestos waste Cost for removal, handling and disposal of asbestos wastes can be splitted into: removal costs of asbestos containing materials from non-contaminated C&D waste

specific handling/packaging/manipulation costs and

final disposal costs (landfilling).

Removal costs For the calculation of future removal costs of asbestos from C&D waste, two different scenarios have to be distinguished: 1. Costs for the removal of cement bound asbestos (asbestos cement).

The typical costs for removal asbestos cement (facades and roofing) by hand (including dis-posal costs) are reported from Western Europe countries in the range of 15 € per m² (which is about 2.000 € per ton). Given the significantly lower labour costs in Serbia a range of 550 € per ton or 66.000 RSD per ton can be assumed.

2. Costs for the removal of unbound and weakly bound asbestos as insulation material and from asbestos/PVC flooring etc. Costs for the removal of asbestos containing PVC-flooring in an average of 260 €/m² (for 10 m²) to 120 €/m² (for 40 m²) were reported in Western Europe. These costs are composed by 30 to 40 % labour costs and 10 to 20% costs for specific equipment (safety equipment, ventila-tion, vacuum cleaner) while the rest (40 to 60%) are final disposal costs. Since the equipment cost as well as the disposal cost will be similar in Serbia only a small reduction due to lower labour cost can be assumed. Thus minimal costs of 92 € per m² can be assumed for Serbia.

Costs for the removal of spray asbestos are reported up to 700 € per m², where about 50% ac-counts for labor costs. Thus removal and disposal costs in the range of 455 € per m² can be as-sumed for Serbia.


Handling/packaging costs The costs for handling/packaging of hard asbestos products can be assumed to be less than 100 €/ton in Western Europe. Total handling and disposal costs for asbestos wastes on licensed landfills in Serbia are reported in the range of 13.000 RSD per ton or approximately 100 € per ton, which is comparable to prices in Western Europe countries. Landfilling costs The cost for landfilling of asbestos wastes can be estimated below 140 €/ton, the disposal of as-bestos cement in the range of 50 € to € 60 € per ton in Western Europe, while the costs for per-manent underground storage are reported in the range of 400 €/ton. Costs for intermediate storage for 90 days are in the range of 4 €/ton (data from Austria and Germany). Permanent underground storage should be the preferred disposal option for asbestos insulating material with other hazard-ous contaminations (e.g. chemicals, mineral oil). Operational costs for other hazardous C&D waste PCB containing C&D waste

In accordance with Article 53 of the Law on WM PCB contaminated debris (EWL code 17 09 02*) shall be disposed of as a POP waste. Since there is no disposal facility available in Serbia for de-stroying the PCB containing waste, export is the most environmentally sound option at present: This is either a thermal treatment plant (high temperature incineration D10 or thermal desorption with incineration of the flue gas D9/D10) or a permanent underground storage (D12). Costs for permanent underground storage were reported in the range of 500 € per ton. Costs for thermal treatment were reported in the range between 450 € and 650 € per ton. Tar containing bituminous mixtures in C&D waste Another hazardous waste stream in C&D waste are tar containing bituminous mixtures. Such mate-rial was mainly but not exclusively used in road construction. Besides this, tar containing mixtures were used as insulation material in buildings. Tar containing material (EWC code 17 03 01* - bituminous mixtures containing coal tar) should be disposed of on landfills for non-hazardous wastes since it is a non-reactive waste with a low leach-ate discharge rate. Disposal costs on licensed landfills are in the range of 100 € per ton. Contaminated soils

ADEME regularly reports operational costs for treatment of contaminated soils. In 2009 prices have been as follows.


Table 63: An example of operational costs for treatment of contaminated soils.

Range of tariffs (before tax) for contaminated soils, de-pending on the hazardous-ness

Means of tariff for contami-nated soils

Storage and treatment facilities for hazardous waste, ISDD

80 à 150€/t 125€/t

Storage and treatment facilities for non-hazardous waste, ISDN

40 à 80€/t 50 €/t

Storage and treatment facilities for inert waste, ISDI

5 à 20 €/t 10€/t

Source: http://www.selecdepol.fr/fiches-techniques/encapsulation-sur-site-et-elimination-en-centres-de-stockage-des-dechets/couts

7.3.2.2 Estimated investment and operational costs for medical hazardous waste

management

Investment costs Short term investment costs till 2020 Thanks to the support of the European Union a country wide system for the collection, transporta-tion and treatment of infectious waste is in place and additional investment for the treatment of this waste stream are not required in the short term. For the management of pharmaceutical and chemical waste, export will remain the only option for at least some years to come. Responsibility for the present management of such waste from collection points within Health Care Institutions (HCI) till disposal abroad, has been taken by the private sector. Additional limited investments are due to the procurement of adequate transport containers, transport vehicles and the establishment of intermediate storage and transfer facilities. Generally spoken, such vehicles and facilities are available in the context of infectious material management. As outlined above, the realization of a small scale incinerator (SSI) for the incineration of phar-maceutical waste and, to some extent, chemical waste from the healthcare sector is planned for the short term. The associated investment costs have been estimated at 1.25 Mio €. Since this SSI is to be realized on BOT or BOO (build and operate) basis the required funds are expected to be provided by the private sector. Long term investment costs after 2020 Once the autoclaves and shredders donated by the European Union have reached the end of their economic lifetime, the long term health care waste (HCW) treatment scenario will have to be real-ized. For its realization, the Government will negotiate with multi-lateral and bi-lateral donors so se-cure funding for at least part of the associated investments. The required investment and funding alternatives to be used in addition to the anticipated donor funding are presented in the table be-low.


Table 64: Required investment and funding alternatives.

Investment Investment details Amount

(order of mag-nitude)

Funding (in addition to donor

contributions) Waste to energy plant for

Belgrade Incinerator (rotary kiln) 50 Mio €

Loan taken out by City of Belgrade

Infectious waste treatment facility for Vojvodina

Large autoclave with in-ternal shredder capacity

± 500 kg/cycle 0.5 Mio €

Vojvodina budget / pri-vate sector

8 Infectious waste treat-ment facilities for central

Serbia

Medium autoclaves with internal shredders ca-pacity ± 300 kg/cycle

1.2 Mio € State budget / private

sector

or

Central Hazardous Waste Treatment Facility

Incl. incinerator, chemi-cal physical treatment

and landfill 100 Mio €

Loan taken out by the Republic of Serbia

An example of investment cost calculation for the two alternatives of medical waste manage-ment in Morocco (planning 2000) is given below Table 65: An example of investment cost calculation for the two alternatives of medical waste management in

Morocco.

Clinical waste to be treated per year 7.500 t/aTotal investment cost for incineration (capacity 2 tons per hour, 5 days per weak, 24 hours per day) on 2.000 m² site

5,6 Mio €

Total operational costs per year (period of amortization is 20 years) 1,13 Mio €Mean treatment sales price 150 € per ton Total investment cost for central sterilization via autoclave (with subsequent landfilling of sterilized residues) capacity 3 tons per hour on 5.000 m² ground

5,1 Mio €

Total operational costs per year (period of amortization is 10 years) 1,28 Mio €Mean treatment sales price 170 € per ton

Operational Costs Operational costs for HCW management is presented in Dinars (2016) and Euro per kilogram of waste respectively. Infectious and sharp waste management Costs of infectious waste management have been determined by a financial working group com-prising representatives of the sector and representatives of the TA-HCW team. The overall costs amount to RSD 160.000 to RSD 200.000 per ton of waste which is 1.300 to 1.600 €/ton). These specific costs can be broken down (in rounded figures) as follows. Table 66: Costs of infectious waste management.

Human resources (operator, drivers, supervisors) RSD 54.000/t 34 % 440 €Electricity RSD 9.000/t 6 % 74 €Water RSD 7.000/t 4 % 57 €Fuel RSD 5.000/t 3 % 41 €Maintenance of autoclave and vehicle RSD 15.000/t 9 % 123 €Waste disposal costs RSD 5.000/t 3 % 41 €Consumables (bags,one-way-containers) RSD 30.000/t 19 % 245 €Depreciation for autoclave, shredder and vehicle RSD 32.000/t 21 % 260 €


Based on research conducted by the TA-HCW team and the NIPH “Dr Milan Jovanovic Batut”, the annual generation of infectious HCW, including sharps, by the public healthcare sector can be es-timated to be 5,000 ton per year an amount which is expected to increase slightly or remain con-stant in the years to come. Total operational cost of treatment and disposal of infectious healthcare waste, including sharps, for the coming years can thus be estimated to be in the order of 6,5 to 8,0 Mio € which is estimated to be in the range of 0.4% to 0.5% of the total public expenditures on health. Other waste streams For other healthcare waste stream only rough estimates are currently available. These estimates are presented in the table below. The estimates are based on a research of waste generation rates conducted by the TA-HCW team and a limited number of quotations / price statements from waste generators and waste treatment service providers. The costs in the table below are therefore indic-ative only. Total costs amount to 0.58 Mio €/a.

Table 67: Estimations of treatment costs for other healthcare waste.

Waste stream Generation rate (t/a)

Treatment and dis-posal cost (RSD/ton)

Cost per year (€/a)

Pharmaceutical Waste 130 250.000 266.000 Hazardous chemical waste

300 > 50.000 *) 123.000

Non-hazardous chemicals 1.425 0 **) 0 **) Pathological waste 75 250.000 ***) 154.000 Overall costs 579.000

*) The costs listed for hazardous chemical waste management will incur in case all hazardous chemical waste will be disposed of in an environmentally sound manner (incinerator). **) The current costs of chemical disposal are limited since large quantities are disposed into the sewer system. For non-hazardous waste this practice might be tolerable if sewage water is treat-ed in municipal waste water treatment plants. ***) Current charges for cremation or burial of patho-anatomical waste vary widely. Some public utility companies even provide the services free of charge while others provide services in ex-change of services provided by the waste generator such as utilization of chapels for funeral ser-vices. The indicated costs are an estimate.

Future cost evolution After realization of the SSI as well as in the longer term, the elements of this cost calculation for HCW management will move: Costs for treatment will decrease with the realization of large scale treatment facilities in Serbia

and with the replacement of small scale steam sterilizers;

Costs for transportation and storage will increase due to the longer transport distances and the higher capacities needed for storage.

But the overall costs for HCW management will slightly decrease with the implementation of this National HCW Management Plan.


7.3.2.3 Estimated investment and operational costs for hazardous packaging waste management

In the context of cost management, it should be distinguished between the collection of hazardous packaging waste:

from industry or from agrochemicals industry and

from households.

Concerning hazardous packaging waste from industry producer responsibility and polluter-pays-principle have been transposed in the majority of MS in such way that industry organizes and pays for such take-back services for its own packages through specific organizations established for this purpose. As regards the hazardous packaging waste from households, EU MSs implemented producer re-sponsibility legislation differently and this has also impact on the local costs for their collection and treatment. In some countries, responsibility for the different fractions of household waste is entirely given to

specific organizations (Austria, Belgium, Finland, France, Germany, Sweden, etc.) and the mu-nicipalities are not participating respectively paying for this task.

In other countries (France, Ireland, Italy and Spain), the municipalities receive a payment but this does not cover the total cost for this task. This means citizens pay a certain portion of waste packaging management by their fees.

In other countries (Denmark, Greece, the Netherlands and the UK), there is no direct funding for the collection of packaging fractions. In Denmark, however, all municipalities are required to in-stall either curbside or bring systems for collection of paper and glass.

There are many variables which should be considered regarding the choice of a packaging waste management system and – more precisely – regarding hazardous packaging waste management. Cost-optimization and financial contributions of the organizations that deal with packaging waste might bring significant financial benefits to the local authorities. In such cases, where the producer responsibility is implemented in a stricter way, the municipalities may charge the households less for the waste collection services of hazardous packaging waste than without such contributions. Operational Costs Some data have been obtained about the cost of such collection schemes. They vary depending on the collection schemes and on technical equipment. For Germany where mobile collection trucks are commonly used in rural areas, the costs are higher than in Austria, where the bring sys-tem to collection yards for recyclable materials is generally predominant. The extraordinary high costs in Luxemburg are due to the extraordinarily citizen friendly take-back system and the extraor-dinarily high density and technical standard of the recycling trucks and yards in Luxemburg. Costs for Bulky Waste and Household Hazardous Waste Collection:

Austria (€/ton) Germany (€/ton) Luxemburg (€/ton) 220 340 - 750 2.840

(Source: Costs for Municipal Waste Management in the EU, Eunomia Research & Consulting Ltd.2001)


Due to insufficient data on generated hazardous packaging waste quantities, the cost of packaging waste management cannot be clearly estimated at this stage in Serbia, At first glance, specific costs seem to be extraordinary high related to the small quantity collected. But due to the fact that such investment and operational costs mainly are dedicated to recyclable non-hazardous packag-ing waste, cross financing of the relatively small hazardous part should be taken into consideration in order to minimize the long term risk of municipal waste being landfills.. Romania can be taken as example: In 2004 approximately 0.85 Mio tons of packaging material were introduced on the market. Thus, the necessary cost for the implementation of the Packaging Directive was assessed at 321.7 Mio €, from which administrative costs were 4.9 Mio € (1,5%) and technical equipment was the rest (316.7 Mio €). From this, investment costs amounted to 214.5 Mio € (two third) and operational costs amounted to 102.2 Mio € (one third). This implies 380 € per ton of packaging waste, an amount that easily can comprise the small share of hazardous packaging waste collection costs.

7.3.2.4 Estimated investment and operational costs for waste oil management

Revenues / contributions to the Environmental Protection Fund According to the GO ON PRODUCTS since 2010 producers and importers are obliged to pay fees to the EPF for mineral and synthetic oils and lubricants placed on the market in Serbia or imported for use by themselves. The revenues of the EPF from the fees (10 RSD per kg, which is 82 €/ton) lev-ied from 219 producers/importers in 2010 amounted to 225 Mio RSD (~2.25 Mio €). In 2011 195 Mio RSD (~1.9 Mio €) were levied from 266 producer/importers. Such contributions paid by the producers and importers of new oils usually do not cover the overall costs of the waste oil management. Examples of current fees paid in countries where such contri-butions are foreseen range between 10 €/m³ to 70 €/m³ fresh oil put on the market. Currently generators of waste oils are paid for their waste oil. Operational cost factors of waste oil management The following cost factors have to be considered in the management of waste oil and oil wastes. Table 68: Cost factors in waste oil management.

Cost segment Details

Collection

Collection at the point of generation (ground, buildings, collection vessels, analyses, etc.) Collection at facilities for small amounts of waste oil from house-holds (ground, infrastructure, staff) Collection and transportation by the collector (transportation trucks, fuel, analytics, etc.)

Storage Intermediation storage (by collectors, ground, buildings, containers, chemical analyses, etc.)

Treatment

Costs for pre-treatment (investment and operational costs for me-chanical pre-treatment or for emulsion splitting, etc., costs for dis-posal of residues, e.g. sludge, concentrates, costs for chemical analyses), - Revenues from recovered waste oil to be used for refining or en-ergy recovery

Cost for final treatment (investment and operational costs for re-refining or use as a fuel in industrial processes, costs for the dis-posal of residues, costs for chemical analysis, etc.), - Savings for replaced energy sources or raw materials


Below up-to date information on rough costs of the most important aspects/steps of waste oil man-agement are provided. It should, however, be stated here, that all information from other European countries have to be seen as approximate costs, which cannot be transferred directly to Serbia. Many factors, such as (legally) required technical standards, geography, general economic devel-opment, salaries etc. may influence the costs significantly. Other smaller operational cost factors must also be integrated into the cost calculations:

Costs for information and awareness raising Information on costs for awareness raising and information of the public is available from Bel-gium, where about 0.5 € per year and citizen to be addressed are spent.

Costs for environmental inspection related to waste oil management Regarding environmental inspection the time requirement per inspection is also of relevance (staff costs). As a benchmark for inspection expenses of (potential) waste oil generators ap-proximately 2 to 5 man hours per inspection and generator per year, and for the inspection of treatment plants and collectors/transporters approximately 8 to12 man hours can be esti-mated. That includes efforts for preparation and conduction of inspection and post-screening (inspection report, announcement).

Costs for administration (e.g. for reporting, registration) and for evaluation and assessment of the performance of the waste oil management system As these activities are usually carried out by various stakeholders (industry, collectors, collec-tive schemes, authorities) and often not dedicated to waste oil solely it is not possible to pro-vide accurate figures on these costs

Savings from prevented rehabilitation measures in case of environmental pollution Oil contaminated soils resulting from improper waste oil management may have to be inciner-ated. Cost information, available from Austria for the disposal of such soils, amount to 230 to 250 €/ton, incl. transport (and Austrian disposal tax). Release of mineral oil to the water body may cause tremendous damages in the ecosystem and may create unforeseen costs risking endangering the financial basis of the enterprise. Long time degradation of environment and subsequent costs often cannot be restituted by as-surances.

Operational costs for waste oil collection

Costs for collection at the point of generation (buildings, collection vessels, analyses, etc.). There are considerable differences in the amount and type of waste oils and other oil waste at the point of their generation. Thus it is not possible to provide information on the costs. Several cost factors, however, are similar to those described below under “costs for intermediate stor-age”

Costs for collection of waste oil from households (infrastructure, staff) Costs for the collection of waste oil from private consumers at collection facilities for separate collection of household wastes are – taking into account, that the so collected amounts are only a little contribution (some percent) of the overall waste oil collection amounts – relatively high-er. This is true even for civic amenity sites, where several waste streams from households are collected simultaneously. From Belgium up-to date data is available on the proportionate costs for waste oil collection at civic amenity sites: It is about 0.10 € per inhabitant and year; costs in-clude infrastructure, personnel and any disposal costs.

Costs for collection, transportation and storage by the collector (investment and operational costs) For collection of different types of generators and wastes (waste oil, oil/water mixtures, emul-sions, solvent/water mixtures, solvents, contents of oil- and grease separators and of grit chambers, etc.) usually trucks equipped with special pumps or suction pumps and enclosed tanks made from steel (or other rust-proof materials) with ADR-approval are used. 270,000 to 310,000 € is the approximate cost for 12 m3 tank-trucks Trucks for transporting of smaller drums and containers (e.g. of 1000 l) equipped with a hy-draulic platform are in general cheaper. Approximate investment cost per truck are 180,000 €.


The operational costs of waste oil transport depend highly on the degree of utilisation of the capacity and distances. Usually operational costs for transport are calculated and charged in terms of hourly rates. 80 € per hour may be seen as a benchmark for operational costs of transporting oil wastes in a tank truck (one driver, excluding any co-drivers and road charges).

Investment costs for intermediate storage of waste oil Investment costs for the general infrastructure (buildings, laboratory, sanitation, balance, con-

struction of collection and traffic areas, surface drainage, oil-separator, fences and ports, etc. are as follows:

Approximate cost for a storage capacity of 400 m3 is 400,000 € (excluding costs for pur-chasing and preparation of land and excluding laboratory equipment for PCB-analyses).

Investment costs for waste oil storage tanks (upright, above ground installed 100 m3 steel-tanks with pipes for filling and emptying, vent pipes, ascension equipment, etc) are approximate 50,000 € per tank.

Investment costs for concrete containment with mineral oil resistant coating (orientation value is 90,000 €.

Investment costs for pumps for filling and emptying of waste oil (incl. filling level indication, over-fill safety, etc. are approximate 80,000 € ( for 2 pumps used for 4 tanks).

Investment costs for basic equipment of small containers such as 200 l barrels, 1,000 l contain-ers are approximate 15,000 €.

Investment costs for activated carbon or bio-filter for exhaust air from the tanks are approximate 40,000 €.

Provided the area needed for all infrastructural elements of a waste oil storage site of 400 m³ comprises around 0.25 ha or 2.500 m² the total amount of investment including space and laboratory amounts to approximately 1,25 Mio Euro. Operational costs for waste oil storage are highly depending on the annual turnover. Approximate costs for an annual turnover of 10,000 tonnes at a 400,000 m3 storage facility are 40,000 €/a; in-cluding costs for chemical analyses of incoming and outgoing waste oil. Investment costs for pre-treatment of waste oil The following investment costs are related to physical-chemical treatment (PCT)-plants for waste oil/water mixtures and liquid oil containing. The costs include all necessary (physical) pre-treatment steps like filtering, decantation, sludge removal etc. Investment costs for the necessary infrastructure like building for the plant, for construction of

storage and traffic areas incl. oil-separator, steel tanks with 100 m3 each, including contain-ments, office building inluding sanitation, laboratory, entrance control, weighing balance and fences, etc. amount to approximately 400.000 Euro (see above)

Investment costs for the proper PCT-plant (acceptance basin, pumps for filling and removal, ul-trafiltration, installation for precipitation and neutralization, chamber filter press, waste water control, exhaust air collection and cleaning equipment) with an annual treatment capacity of 5,000 tonnes and with an integrated storage capacity of 200 m3, are 950,000 €; this can be seen as an approximate cost for overall investments excl. land.

Additional costs have to be considered. A steel panel sedimentation tank of 30 m3, incl. skim-mer, level indication and other secondary equipment may cost about 35,000 €. An average centrifuge (5 m3/h), including a three-phase-decanter, may cost about 70,000 €. A usual flota-tion system (3 m3/h) may cost additional 30,000 €.


Provided the area needed for all infrastructural elements of a waste oil treatment facility comprises around 0.25 ha or 2.500 m² the total amount of investment including space and laboratory amounts to approximately 1,5 Mio €. Combined with an appropriate storage facil-ity the investment amounts to 2,7 – 3 Mio €. Operational costs for the pre-treatment of different oil containing liquid wastes in PCT-plants

highly depend on the rate of capacity utilisation. Approximate costs for the treatment of emul-sions may be about 55 €/ton input material without treatment of waste waters, or 60-75 €/ton incl. treatment of resulting waste water.

Operational costs of physical treatment only are comparably lower: Sedimentation is 5 €/ton, centrifugation is 10 €/ton and flotation is 8 €/ton.

Any necessary chemical analyses conducted at a PCT-plant (waste input, output, waste water, process analytics) may cost about 7 €/ton input material.

In order to reduce investment and operational costs of PCT- plants, they should preferably be combined with waste oil collection and storage facilities. Costs and revenues for final treatment and re-use of waste oil Generally spoken, there is a market demand for waste oil bearing in mind that use of waste oils for energy recovery in cement kilns provides lower operational costs of production, and thus provides a higher level of competitiveness in the domestic and regional markets. This is a widespread expe-rience of cement industry in western EU countries. Investment costs for secondary oil refining are substantially higher. As long as authorities don’t ex-ecute constraints to the waste oil market by stringent regulations, there is no chance in Serbia to revitalize the closed-down re-raffination facility. For individual oil wastes – according to their quality (contaminants, content of recoverable oil re-spectively calorific value) - the prices for disposal vary significantly. In general prices paid for dis-posal of oil wastes, respectively the revenues achieved, reflect the market situation with demand and supply at the given time and location, which is influenced by many factors. A general overview of the economical values (positive/negative) of different groups of oil containing wastes is provided in the following table.


Table 69: An overview of the economical values (positive/negative) of different groups of oil containing wastes.

Waste oil / oil waste Description feasable treatment Eco-nomic value

Used transformer oils and heat transfer flu-ids

High recycling quality when separat-ed properly

Recycling +++

Used hydraulic oils High recycling quality when separat-ed properly

Recycling ++

Used motor oil/ lubri-cants

High recycling quality when collected separately without other liquids (sol-vents, gasoline, brake fluid, etc.)

Recycling +

Used oil filters Mixture of metal, paper, oil. If they are collected separately (in garages) recovery of metal and oil is feasible

Shredding, sorting metal recovery, oil re-covery Recovered oil: Recy-cling

-

Oil containing sludge from tank cleaning

Complex waste stream containing metals, water, and oil

P/C treatment Recovered oil: Recy-cling or Energy Re-covery

-

Content from oil/water separators

Small quantities of oil in inorganic material (sand, etc.)

P/C treatment Resulting oil concen-trate: Energy Recov-ery

--

Oily wastes from sur-face treatment (waste group 12 01)

Used machining emulsions with oil contaminated metal fines

P/C, mechanical treatment metal recovery, oil recovery Recovered oil: Energy Recovery

---

The prices/revenues may range from costs of 250 €/ton (e.g. for oil contaminated soils) to reve-nues of up to 100 €/ton paid for high quality waste oil suitable for re-refaining to lubricants. Com-mon gratifications for waste oil in Germany are (Ökopol 2006): Means sales revenue for re-raffination 60 €/ton Means sales revenue for waste for energy re-covery

30 €/ton

7.3.2.5 Estimated investment and operational costs for batteries and accumulators management

According to the GO on products producers and importers of batteries and accumulators are obliged to pay a fee for batteries and accumulators placed on the market in Serbia or imported for use by themeselves. In the first 10 months of 2011 about 188 Mio Dinars (1.53 Mio €) were col-lected by the EPF for the market input of batteries and accumulators (EPF, 2011). In total 463 pro-ducers/importers paid fees. Based on these numbers, annual revenues for batteries and accumula-tors can be calculated as being about 225 Mio Dinars (1,83 Mio €) per year. There is no infor-mation on the shares of money levied for the different types of batteries or the amount (kg, t) of batteries and accumulators covered by these revenues.


Based on GO on incentive funds the former Serbian Environmental Protection Fund (EPF) intend-ed to pay incentives for the reuse, recycling and use of waste batteries and accumulators. Incen-tives were to be paid to treatment plant operators concerned. The total amount of the incentives therefore had been determined on the base of information from operators and experiences from other countries. They have been calculated by representatives of the EPF, the Chamber of Com-merce and representatives from the MEMSP. Unfortunately, such information was not available. Investment and operational costs for automotive batteries and accumulators (lead-acid-batteries) management It is estimated that there are no major additional investment costs needed for the collection and treatment of automotive batteries and accumulators because: the infrastructure for collection works and operates on 4,000 container places;

the containers are given and containers are available on all 4,000 container places;

the transport network works and treatment operators (recyclers), sub-contractors of treatment partners or ‘free collectors’ (from formal and informal sector) share the benefit;

treatment capacities are available.

Formal collection network should be further completed in order to prevent soil contamination at in-formal treatment sites. Moreover, there will be probably a certain additional need for investments for the pre-treatment of lead-acid accumulators especially for the separation and treatment of the evacuated acids. But it can be assumed, that these investments easily can be paid by the formal treatment sector of such waste lead-acid accumulators taking into account the enormous benefits achieved by this activity. Investments to meet and keep environmental requirements for the final smelting process (e.g. stricter emission limits, more stringent disposal options for residues etc.) will be required from the lead smelter, independently of the use of waste lead accumulators in the facility. In general the total operational costs for automotive batteries and accumulators as well as for in-dustrial batteries and accumulators tend to be small related to the revenues of their sale. Estimated investment costs for portable batteries and accumulators management For the collection and treatment of portable batteries and accumulators important investments are necessary because no infrastructure for such waste is present in Serbia. Additionally, there are no revenues to be achieved from this activity; in the contrary: This part of the collective schemes usu-ally is quite expensive. Following investments / investment costs for the collection of portable batteries and accumulators have to be considered: The infrastructure for the collection of portable batteries and accumulators at municipal collection

facilities is missing - there is no structure for the collection of hazardous wastes from house-holds given at all. Investments will not be dedicated for portable batteries and accumulators on-ly, but for all kinds of recyclable and hazardous wastes from households. Therefore it is not feasible to calculate investment costs for portable batteries and accumulators separately.

Such ‘additional’ investments for the collection of portable batteries and accumulators comprise space (some square meters of area) and protection (roof) and storage capacity ( containers ) for collection. These ‘additional’ investments should be covered by the producers/importers of such batteries or EEE products taking into account their producers responsibilities in the frame of collective schemes.

For retailers there are no ‘investments’ in infrastructures necessary taking into consideration that only small boxes will be provided;


‘boxes’ / ‘small containers’ to be provided to retailers and other collection points may dependi on the amount collected and the available space for collection boxes. Costs for collection con-tainers, which are acid proof amount to 35 € to 50 €per unit and simple cardboard boxes for the collection from retailers and other collection points amount to 0,85 € / unit only.

Receptacles / containers (e.g. 200 l barrels) for collection facilities and/or interim storage sites will be necessary as well. The number of necessary receptacles has to be determined on base of the collection and storage system planned. These costs depend on the use of (new) multiple use containers and/or the use of (waste) secondary use containers (i.e. from other preceeding purposes).

There are no investment costs for transports of portable batteries and accumulators necessary due to the fact that there are several operators with an appropriate permit for the collection and transport of WEEE are available. Their car fleet might be used and additional permits for portable batteries and accumulators might easily be approved. Storage facilities are needed for fulfilling all other waste batteries’ obligations. There are different options to store portable batteries and accumulators: Interim storages within e.g. municipal collection points or within retailer’s shops and facilities. In

all cases containers and a definite area have to be provided for the storage of portable batter-ies and accumulators. There will be ‘additional’ investments for the collection points within re-tailers’ facilities only. Such ‘additional’ investment costs shall be covered by the produc-ers/importers of batteries and from their management systems respectively.

The proportional costs of investment for batteries storage (and collection) within municipal col-lection points are integrated into the overall costs of such municipal facilities and will be low.

Regional (centralized) storage facilities: Such storage facilities usually are integrated into treatment facilities or prepare for exportation. Therefore such investment cost might be consid-erable due to security demands, fire and explosion protection measures etc. But such regional collection, storage (and recycling) centers share these costs for many kinds of waste. It makes therefore no sense to calculate investment costs for portable batteries and accumulators only.

The treatment of portable batteries is subdivided into two steps: 1. The first step consists of sorting facilities separating different types of batteries for further re-

cycling or disposal steps. 2. The second step are technically high standing dismantling and extraction processes for the

recycling of secondary raw materials; such processes differs significantly for different batterie types..

There are no treatment facilities for portable batteries and accumulators in the Republic of Ser-bia at present, neither first step, nor second step facilities. Concerning the investment into one sorting facility for portable batteries in Serbia, such costs are relatively low, because it consists of a simple manual sorting work on a sorting belt or a sorting table. This unit might easily be inte-grated into a WEEE dismantling facility, without producing remarkable additional costs. Estimating the upcoming amounts of portable batteries and accumulators to be collected in the Republic of Serbia, it is estimated that the installation of any secondary treatment plant either for Cadmium extraction or for Zn in Serbia doesn’t seem economically feasible. Such investment costs are much depending on the technologies applied and the facilities already in place (smelters, distillation plants). Neither in short term nor in medium term should such facilities be planned. Ex-port of such waste should be preferred.


Estimated operational costs for portable batteries and accumulators Incentives paid by the former EPF for portable batteries collection and treatment could be a refer-ence for related operational costs in the Republic of Serbia. The values given are with 135 Di-nars/kg or 1.100 €/t respectively quite high and might include some start-up costs.

Other minor costs for management of waste batteries and accumulators should be taken into ac-count, but usually are covered by producers/importers or by management systems respectively. Such costs are: Costs for data infrastructure (register, organization) and costs for the ‘Clearing house’, costs for awareness building and collection campaigns, Information etc Examples for operational costs for portable batteries and accumulators from German battery recy-cling facilities (2005) are given in the table below (in €/ton). Table 70: Examples for operational costs for portable batteries and accumulators from German battery recy-

cling facilities.

Ni/Cd batteries from industry (emergency gen-erators, transport systems), total costs

2.000

Ni/Cd batteries from industry (emergency gen-erators, transport systems), costs of Cd-distillation service only

450

Li-Ion and NiMH-batteries from mobile phones, total costs

650 - 1050

AgZn-, NiCd-, and Li batteries, total costs 4.500Zn-Carbon batteries from road construction sec-tor only, total costs (landfilling)

270

All types of portable batteries – retailers collec-tion system

800

7.3.2.6 Estimated investment and operational costs for WEEE management

Revenues / contributions to the Environmental Protection Fund According to the GO ON PRODUCTS since 2010 producers and importers of electrical and electronic products are obliged to pay fees for electrical and electronic products (EEE) placed on the market in Serbia or imported for use. Currently the total yearly revenue from the fees levied for placing EEE on the market amounts to about 1,100 Mio dinar (9 Mio €). Investment and operational costs - structure and cost factors The following cost factors have to be considered in the management of WEEE: 1. Collection, storage and transport

Costs for municipal waste collection facilities i.e. collection points (site, infrastructure, staff) Costs for transportation from first level, e.g. municipal, collection sites to regional transfer

and storage facilities Costs for the operation of regional transfer and storage facilities (private) Costs for transportation from regional transfer and storage facilities to treatment (disman-

tling) plants (second level transportation 2. Treatment

Costs for first stage (mechanical) treatment (sorting, dismantling, de-pollution) Costs for transportation from first stage treatment to disposal, recycling or export Costs for final disposal of residual fractions (incineration, landfilling) and/or costs for ship-

ment (packaging, container, transpot documents) Revenues can be achieved from recovered metals, glass, plastics Revenues from re-use of appliances (occasionally)


Additional cost elements occur during operation:

Management system (collective schemes) costs, like Staff costs Costs for advisors (legal, technical, PR, commercial, etc.) Education and public awareness raising Overhead (IT, office rents, etc.)

Depending on the legal framework for the WEEE management system, additional costs, such as contribution to the costs of a “Clearing House”, of awareness raising activities, of operating regis-ters, etc., may arise.

The share of the individual cost factors compared to total operational costs differs significantly be-tween individual WEEE categories. The overall costs for the management of WEEE from the indus-trial sector are usually lower than those for the management of WEEE from households, because: the collection is cheaper (often taken by the treatment plant operator);

costs for storage infrastructure are lower (often taken by the industrial generator);;

the quality is better and the type is more uniforme which increases the share of re-used equip-ment which generates revenues instead of costs;

more uniforme WEEE may allow higher efficiency in treatment .

Reasons for differences in the costs for collective schemes in different countries are: Differing efficiency of the collection system. If WEEE are collected at collection sites together

with several other wastes such as batteries, metal, paper, plastics and bio-waste, costs are usually lower;

Differences in salaries in different countries;

Differences in treatment standards that have to be complied with. Some countries have legally binding treatment standards going beyond the requirements of the WEEE Directive, others not;

A lack of treatment infrastructure for particular WEEE types, such as gas discharge lamps, may lead to higher costs for exports;

Volatile market prices for valuable materials in general.

Comparison of overall costs for the WEEE management The following table compares the overall costs of the WEEE management in selected European countries (cost calculations by collective schemes) with the incentive funds for treatment of WEEE in Serbia in 2011 as specified in the GO ON INCENTIVES (“Official Gazette of RS" no. 88/2009, 67/2010 and 101/2010). Incentives to be paid for reuse, recycling and recovery (i.e. treatment, without collection and transportation) of particular WEEE categories were specified in the GO on incentive funds. The comparison of costs for WEEE treatment in Austria and Bulgaria with the Serbian incentives below reveals that the costs for treatment of WEEE types such as cooling appliances, gas dis-charge lamps and screens are comparably lower.


Table 71: Comparison of costs for WEEE-treatment in Austria (Collection Scheme ERA, 2009; info on flat-

screens from Salhofer et al (accepted for publication)) and in Bulgaria (EMEPA, 2009) with incentives for re-

use, recycling and recovery of WEEE in Serbia (Serbian MoE, 2010)

Large ap-

pliances Cooling appli-ances

Screens Flat-screens

Small ap-pliances

Gas dis-charge lamps

Austria costs in 2009

€/t 70 150 160

359a-755b 70 600

Bulgaria costs in 2009

€/t 82 255 290

204 900

Serbia incen-tives in 2011

RSD/kg 40*/12** 100 35#

80 54°/25°° 120

Calculated as € in prices of 2016

€/t

320*/ 96** 800 280#

640

432°/ 200°° 960 *…large household appliances **…heating devices °…IT&T (small appliances) °°…consumer equipment (small appliances) a…Flat-screen-TVs b…Flat-screen-Monitors

Costs specified for the WEEE collection system Collection centers in municipalities / cities The highest costs when establishing a WEEE collection system may arise in setting up a system for collection of hazardous wastes from households in general, which currently does not exist in Serbia. The costs for collection of WEEE from households are additional costs compared to the overall costs of establishing a system of municipal collection points for recyclable materials.

The overall costs depend on the costs for site, for the technical equipment, such as buildings, con-tainers, weighing equipment, and staff. Assuming, that the costs for collection of WEEE in Serbia are half of the costs in Austria, the costs are estimated to be about 1,500 € per year and per full size municipal collection site. According to the Action Plan of the Waste Management Plan 19 municipal collection facilities for WEEE should have been established in the 10 biggest Serbian cit-ies by 2016. Furthermore, it was determined, that by 2016 additional 80 collection facilities in rural areas should have been established. These facilities may provide less collection containers. etc. than those in urban areas. Assuming, that the costs for collection of WEEE in Serbia are half of the costs in Aus-tria the costs are estimated to be about 500 € per year and per small size municipal collection point. In Austria, municipalities get refund for their ‘additional’ efforts for the collection of WEEE by the collective schemes. This so-called ‘infrastructure contribution’ covers the costs for the technical in-frastructure (area, buildings, balances, collection containers, etc.) but also for the staff performing the take-over and manipulation of WEEE. The contributions are determined as lump sums for large, fully equipped, and small, partly equipped, collection sites – and additionally specifying dif-ferent WEEE-collection categories. The level of the ‘infrastructure contribution’ is agreed between the Austrian clearing house, the associations of municipalities and cities and other stakeholders on a regular basis:


Currently it is: 3.101 € for a large, fully equipped collection site (area of at least 183 m2, defined number and

type of collection containers) and

979 € for a small, partly equipped collection site (area of at least 48 m2, defined number and type of collection containers)

These contributions can decisively diminish the overall municipal operational costs for collection points in municipalities. Regional waste management centers Apart from these first level collection facilities it was determined, that additional regional waste storage and transfer centers should be built and operated by privat sector. Many other hazardous and non-hazardous waste types may be handled here. Such regional storage facilities will be equipped with appropriate infrastructure to serve as a second level collection and transfer facility for WEEE. The investment costs for such facilities are estimated to be about about 1 to 3 Mio € (see chapter 7.3.1.2); the share of WEEE storage will depend of the decision of operators; the me-dium operational costs of such a facility amount to 50 €/t, where storage of WEEE belongs to the waste with lower operation costs.

Storage and transfer from retailers Costs for take-back at retailers are usually low and covered by the retailers. Additional investment costs for WEEE transport are not expected as many operators have a permit for the collec-tion/transport of WEEE and the required car fleet in order to bring such WEEE to their proper facili-ties. If municipalities decide to offer additional pick-up services for collecting WEEE, additional in-vestment is needed for transport vehicles; operational costs of such service may be significant. Costs specified for the treatment of WEEE Investment costs for the treatment of WEEE As Serbia already has treatment facilities for the first treatment step of all types of WEEE, no fur-ther investments are expected in the near future. Additional investment needs will arise when completed collection infrastructures begins to show its effects and with stricter standards, e.g. in connection with higher collection targets or when limita-tion of gaseous emissions, are adopted, which require additional air cleaning equipment (e.g. for treatment of cooling and freezing equipment) etc. Operational costs for the treatment of WEEE For calculation of net operational costs for WEEE in Serbia, an approximation is necessary about the relative distribution of different WEEE categories in Serbia. The following distribution (in weight percentage) has been assumed from WEEE waste quantities collected in Serbia and comparable MS countries: 27% large appliances,

27% small appliances,

25% screen equipment,

20% cooling appliances and

1 % gas discharge lamps


Net costs for treatment of WEEE from households in Austria have been taken to calculate means of operational costs for the categories collected. These costs are:

WEEE category Specific costs (or revenues) large appliances - 25 to - 5 €/t cooling and freezing appliances 120 - 150 €/t CRT-screens 140 - 190 €/t flat-screens 400 - 750 €/t mixed small appliances 50 - 110 €/t gas discharge lamps 550 €/t

From this, medium treatment costs are estimated with 125 € per ton of WEEE collected from households. The collection objectives determined in the Action Plan of the Waste Management Plan are as fol-lows: 2 kg/inhabitant by 2016,

3 kg/ inhabitant by 2017 and

4 kg/ inhabitant by 2019.

From this and from the above mentioned specific costs from Austria, the overall yearly treatment costs for WEEE collected from households are estimated to be € 1.4 Mio by 2016,

€ 2.1 Mio by 2017 and

€ 2.8 Mio by 2019.

However, differences may occur due to deviations in individual cost factors in Serbia, such as lower salaries or higher costs for exporting selected hazardous components. Estimated costs for administration of the WEEE management system (= collective schemes or Fund) Experiences from Austria show that a small percentage of the total turnover of a collective scheme (= fees collected) is required for administration purpose. Estimated other costs for management of WEEE Further costs, such as costs for registration, costs for running a clearing house etc. may accrue in the context of WEEE management. They may be covered by producers/importers (e.g. costs for registration), by management systems (e.g. ‘Funds or collective schemes), by waste management fees and/or by national/local budgets dedicated to environmental issues. Examples are:

Costs for data infrastructure/ IT-services: The costs for operating the EEE register and data management system currently could amount to 100.000 €/a and should be paid by collective schemes.

Costs for a clearing house: Collective schemes contribute with 700.000 to 800.000 € per year to the costs of the clearing house. This includes also the costs for awareness raising activities. In 2010 in Austria 5.5 €cents/inhabitant were dedicated to these activities.


Future cost influencing factors Regarding the future development of costs for WEEE management in Serbia several influencing factors have to be considered:

higher treatment standards, e.g. for waste derived fuels (RDF) and for landfill threshold values, will increase necessary effort in WEEE waste treatment and therefore costs for WEEE treatment;

establishment of state-of-the-art treatment facilities for certain WEEE categories (second step treatment after dismantling) might increase revenues and lower costs for export;

improved sorting technologies may increase material recovery and revenues from such material streams;

shared use of the infrastructure for the collection of several separate waste streams will lower the specific costs for collection of WEEE.

Several EU Member States made the experience, that after the WEEE Directive coming into force, treatment costs for WEEE continuously declined. This was predominantly a consequence of in-creasing competition.


7.3.2.7 Estimated investment and operational costs for end-of-life-vehicels

Investment costs

In the National Waste Management Strategy from 2010 the situation of the management of ELV is analysed. For the year 2019 a quantity of 124,000 t ELV is expected and for the period 2010 – 2019 an amount of 30 Mio € is estimated to be necessary for the management of ELV. From the estimations realized in the SHWMP for ELV it can be concluded that the annually gener-ated quantity of ELV in Serbia is between 40,000 and 42,000 tons only. This implies investment costs of one third of the above mentioned costs which is 10 Mio €. Dismantling and shredding in-frastructure for ELV should develop progressively with increasing demand. Short and medium term investments of 2 to 4 Mio € for approving existing installations should be foreseen. It is expected that systems and facilities for the management of ELV, being under the responsibility of private sector, will almost completely be funded by private sector from its own capital and/or long-term commercial loans. (source: SWMP ELV 2016 06 24) Operational costs The French Environment and Energy Management Agency (ADEME) has estimated the cost of depollution of ELV at 30 € per ELV. The Stakeholder Group for the “Study to examine the benefits of the End of Life Vehicles Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery under the ELV Directive” place the average operational cost of de-pollution and essential dismantling at 40-80 € per ELV, including administration costs. British Metals Recycling Association estimates are that ELV shredders produce 72% of ferrous metal, 4% of non-ferrous metal and 24% of shredder residue. Such calculations of metal recov-ery at the shredding stage are highly influenced by the fact that ELVs are typically mixed with other waste streams during the shredding process. The French Environment and Energy Management Agency reports income of 90-95 €/t for ferrous metals and 200-350 €/t of non-ferrous mix re-covered from shredders, representing an average income of 86-95 €/t of ELV body shell entering the shredding process. Shredder residues traditionally have been landfilled in the EU. In France, ADEME has reported the cost of landfill at 50-55 €/ton, including tax (9.15 €/t. Many dismantlers in France export body shells for shredding in Spain where the cost of disposal is lower. In Hungary, landfill costs for shredder residues are currently 40 €/t, according to the recycling consortium Car-Rec. In the UK, the current cost of landfill shredder residues is approximately £15-£20 per ton (plus the current landfill tax of £18). The total current cost of landfilling is therefore 52-59 €/ton). In the Nether-lands, Dutch government charged 84 €/t for landfilling shredder residues from 2008. There is a lack of reliable and up-to-date data comparing the costs of landfill of automotive shred-der residues in different EU Member States. Available data highlight wide variations in landfill costs across the EU. Incineration with energy recovery is seen as a potentially attractive option in many Member States, but is usually limited by a shortage of capacity. Some Member States, Switzerland and Ja-pan banned landfilling of shredder residues; they must be treated or incinerated. Since 2000 shredder residues have been co-incinerated with municipal solid waste as a transitional solution and a shredder residue treatment plant has been developed. The Swiss Auto Recycling Associa-tion quotes operational costs of 149-259 €/t for transport and incineration in Switzerland and 223 € /t in Germany.(source: SWMP ELV 2016 06 24)


7.3.2.8 Estimated investment and operational costs for PCB-waste management

PCB containing transformers From the National Railway Company 473 transformers had been analyzed during in-depth invento-ry out of which 17 were identified as PCB-containing. The weight of the PCB content above 50 ppm is around 3 tons, while the total weight is around 14 tons. Serbian Railways have participated in Environmentally sound and final disposal of PCB’s in cash with amount of 15,665,770 dinars (about 127,000 €). Cost for planned activities of treatment of PCB-containing equipment and purchase of new equipment for replacement, estimated on a basis of a study „Identification of all sources of pol-lution by PCB waste and environmental impact assessment and its removal from the premises of the Serbian Railways” is 208,000 €. Estimated amount of other, indirect costs (salaries of staff, transport cost, daily fees.) is 17,770 €. Amount of 225,770 € is related to the estimated cost of re-moval of 17 identified PCB-containing transformers and for purchasing of new ones, as well as to the cost of all regular activities that will be undertaken for environmentally sound management of above mentioned equipment. Total estimated cost for environmentally sound management of PCBs in jsc. Serbian Railways is: 393,217 €. Based on the inventory and additional examinations performed during the Project Preparation Grant phase, the expected quantities of the PCB containing transformers are estimated to 10.000 in Serbia, with a fluid mass of around 2.000 tons of PCB contaminated fluid oil and a total mass of contaminated equipment of around 8.000 tons. Taking into account the means of above mentioned costs from National Railway Company the overall costs of environmentally sound management of PCBs is 225 Mio € from which the amount of 90 Mio € is related to the estimated cost of removal of 10.000 estimated PCB-containing transformers and for purchasing of new ones, as well as to the cost of all regular activities that will be undertaken for environmentally sound management of above mentioned equipment. As an example, the calculated costs for the evacuation of PCB transformers in Tunisia can be shown; these calculations have been established in the frame of a Worldbank Cooperation Project in 2011 :

The total costs amounted to 3.500 € /per ton of PCB contaminated waste

Due to recycling of copper, aluminium and iron, revenues of 700 € /per ton can be achieved

The net costs amounted therefore to 2.800 € /per ton. Another cost example can be taken from this project: For a transformer of 400 KVA and a total weight of 2 tons, the containing PCB oil (Ascarel) amounted to 0,95 tons. The cost of disposal (export for incineration and underground disposal) of such transformer has been 5 600 € ; the replacement by a new one was 12.300 €, with 10.600 € for the replaced equipment and 1.700 € for the installation works. Another technology could be the use of physical-chemical treatment technology, specifically the de-halogenation of PCB; in this process chlorine is replaced by polyethylene glycol ; the costs are 5.000 € per ton (2011). Evaluations concerning the stepwise replacement of contaminated PCB transformers resultet in to-tal costs for Tunisian PCB elimination program (1700 tons from which 600 transformers and 600 condensators) between 3,6 to 7,2 Mio €.


7.3.2.9 Estimated investment and operational costs for POP waste management

Investment Costs It seems to be probable that Serbia’s POP elimination will be based on the establishment of one high temperature incinerator for all hazardous industrial and medical waste which will be suitable for pesticides, PCBs and other POP waste as well. The cost estimation for such incinerator see above. Operational Costs The operational costs depend on the requirements to be fulfilled for such waste incineration (choice of technology and decision about emission limits), on the time schedule of remediation of contami-nated sites, and on the final program concerning the phase out of PCB-equipment. Data for hazardous waste treatment costs within the EU, indicating range of operational costs for POP-waste can be given in the following range:

Costs for thermal treatment of contaminated soils in specialized installations (e.g. Germany, the Netherlands) range between 160 €/ton and 320 €/ton.

Costs for incineration of PCBs waste range from 300 €/ton to 600 €/ton, depending on the PCBs concentration.

Costs for incineration of mixed solid hazardous waste range from 200 €/ton to 400 €/ton

Costs for solidification and landfilling of hazardous waste range from 180 €/ton to € 320 €/ton

Costs for permanent underground disposal are about 300 €/ton and more, depending on the size of the packaging.

Costs for the underground use as construction material in salt mines (recovery R5) range from 150 € /ton to 250 € /ton.

These costs reflect the negotiated costs/prices depending on the total mass of waste to be dis-posed of and not the catalogue price.


7.3.3 Conclusions

Modern Hazardous Waste management, as defined in this strategy, contributes to compliance with three main EU standards – …the Landfill Directive, the IED Directive and Waste Framework Di-rective. Waste management is considered to be an area requiring heavy investment and a long pe-riod required for implementation. Therefore, strategically it must be taken as an area of priority and long-term investment.

7.3.3.1 Total capital investment in Serbia

This chapter outlined the estimated investment and operational costs of the construction and oper-ation of hazardous waste management facilities, needed in Serbia. The estimated costs comprise the implementation of the facilities mentioned above (chapter 7), which is:

Construction and operation of local collection points on municipal level accomplishing the function as collection points of hazardous and non-hazardous household waste;

Construction and operation of regional storage facilities, preferably integrated into other treat-ment and disposal facilities like physical-chemical treatment and incineration plants, landfills and C&D waste recycling plants;

Construction and operation of a physical-chemical treatment plant, complemented by plat-forms for the preparation of waste derived fuels (for cement industry and other industrial thermal processes);

Construction and operation of incinerators and/or establishing a system of energy recovery from hazardous waste in the cement industry and other industries that have the possibility of conducting thermal treatment;

Construction and operation of one hazardous waste landfill and/or the establishment of equivalently equipped cells within other landfills and

Establishment of a management system (collection, storage, treatment, recycling and disposal) for specific waste streams, like storage and treatment of waste oils, recycling facilities for WEEE and dismantling and recycling facilities for ELV, sorting units for batteries and accumula-tors, collection, storage and treatment facilities for medical waste, for PCB and other POP waste.

The analysis has been implemented at incremental basis, identifying systems, plants and equip-ment that will be needed in future in addition to already existing (few) hazardous waste manage-ment systems that meet the legal requirements. A step by step approach has to be chosen not on-ly in order to smooth immediate investment demands, but also in order to complete infrastructure after demand, knowledge and know-how. Therefore short term and intermediate term investments have been distinguished. The costs were estimated in EUROs, in permanent prices from 2016. Serbian prices have been adapted to the exchange rate of 1 Euro is 122 RSD. 1. No important additional investment costs necessary for collection infrastructure. Equipment

will be adjusted step by step with increasing demand and revenues. 2. Investment costs for storage and transfer facilities (ST) are composed of price of land, in-

frastructure installations, a weighing bridge, laboratory, administration building, storage build-ings and storage equipment. All this amounts to 3 to 6 Mio € for a small scale store and 10 – 15 Mio € for a large scale storage facility. They should be connected with corresponding treatment capacities and integrated into treatment facilities. Capacities will develop step by step with increasing capacity of treatment facilities.

3. The investment costs for physical-chemical treatment (PCT) plants depend on the tech-nology applied, the choice of the site, the plant size and the complexity / variety of waste to be treated. The design of the processes depends on the “quality” of the produced residues and the “quality” of the waste water produced. Investment costs for PCT in Serbia range from 5 to 10 Mio € for a small scale facility and 12 – 20 Mio € for a large scale treatment facility. Con-siderable reduction of the operational costs can be achieved by good choice of process steps.

4. Investment costs of a new incineration plant (INCIN) are in the range of about 50 to 80 Mio €, depending on the size of the plant and the exhaust gas treatment required. Cement industry


(CK) starts from much lower investment costs of < 30 Mio €, depending on the exhaust gas treatment system required and the variety of waste being used. Treatment of used tires and of waste oil start with investments of 4,5 to 6 Mio €.. Investment costs for the preparation of secondary fuel (RDF) for cement kilns amounts to approx. 4 Mio €.

5. Investment costs of a hazardous waste landfill (LF) depend - due to its large surface - from the site installation costs and from the technology applied. Stabilization (STAB) units might be necessary before landfilling certain sludges; investment costs are around 2 Mio €. Considera-ble reductions of the operational costs can be achieved by sufficient capacity of the facility. Investment costs of a new hazardous waste landfill in Serbia are in a range of about 5 to 10 Mio €. Limited capacity for landfilling of hazardous waste in separate compartments of Serbian municipal landfills in the range of 15.000 tons per year can be made available in near future; this could decrease necessary investment volume decisively. New landfilling capacities could also be located within industrial areas where such landfilling capacities are needed. They might be docked to industrial facilities where necessary experience in hazardous substanc-es’ handling, space and equipment are available. This can decrease the needed investment volume as well

Special waste streams 1. A system for infectious waste (INF) is in place and no additional investment is required in

near future. On the long term, additional investments for infectious material are necessary: Investment costs for a center of sterilization via autoclave (with subsequent landfilling of sterilized residues), is slightly less expensive (5.1 Mio €) than the incineration (5.6 Mio €).

2. A state-of-the art waste oil treatment facility (OIL) including laboratory amounts to approxi-mately 1,5 Mio €. Combined with an appropriate storage facility the investment amounts to 2,7 to 3 Mio € (see 7.3.2.4). Waste oil re-use as secondary fuel is attractive for both parts, due to the minimum pre-treatment effort needed. Investment costs for secondary oil refinement are substantially higher. As long as regulations don’t forbid it, there is no chance in Serbia to revitalize the closed-down re-refinement facility.

3. Intermediate storage of asbestos waste (ASB) should preferably be integrated into storage and treatment facilities for C&D waste. The investment costs for a separate storage compart-ment for asbestos contaminated C&D waste can be estimated with 10.000 to 15.000 € per storage unit (based on experiences in Austria). Since asbestos waste can be landfilled in specific compartments of municipal landfills, the additional investment costs for such com-partments are limited. Investment costs for a landfill for non-hazardous wastes in Europe are in the range of 10 €/m³ to 25 €/m³.

4. New facilities with appropriate technologies applied for WEEE-pretreatment will cost between 1 and 5 Mio €. As Serbia already has treatment facilities for the first treatment step of all types of WEEE, no further investments are expected in the near future. Additional investment needs will arise when collection infrastructures is completed and with in-creasing technical standards.

5. There are no treatment facilities for portable batteries (BAT) and accumulators in the Repub-lic of Serbia at present. The investment costs for one sorting facility for portable batteries in Serbia, are relatively low (<1 Mio €), because it consists of a simple manual sorting work on a sorting belt or a sorting table. This unit might easily be integrated into a WEEE dismantling fa-cility, without producing remarkable additional costs.

6. From the estimations realized in the SHWMP for ELV it can be concluded that the total in-vestment costs for an integrated system will be approximately 10 Mio €. Dismantling and shredding infrastructure for ELV should be developed progressively with increasing demand. Short and medium term investments of 2 to 4 Mio € for approving existing installations should be foreseen.

7. Concerning hazardous packaging waste from industry producer responsibility and polluter-pays-principle have been transposed in the majority of MS in such way that industry organizes and pays for such take-back services for its own packages through specific organizations es-tablished for this purpose. Costs are not reported till now.


Overall costs for the integrated hazardous waste management system in Serbia are subdivided in short term priority investments and medium term additional investments to complete the manage-ment system in sustainable way: Estimated costs for short term investment program is about (5x5 ST + 10 PCT + 4 RDF + 15 CK + 5 LF = 59 Mio €. Examples from other countries prove that such investment can be minimized by concentrating sev-eral of such hazardous waste management activities in central treatment and disposal facilities. As an example of the investment costs for a treatment and disposal center in Morocco has been presented above, where investment costs of 34 Mio € have been calculated for an integrated treatment and disposal center (without incineration unit).

Additional costs for a medium term investment program are (2 x 10 ST + 10 PCT + 80 INCIN + 10 LF + 2 STAB = 122 Mio €. Table 72: Short and medium term investment in hazardous industrial waste management facilities.

Hazardous waste treat-ment installations

Short term investment Medium term investment

collection infrastructure Neglected, see chapter 7.3.1.1

Neglected, see chapter 7.3.1.1

storage and transfer facili-ties

3 to 6 Mio € = (5x5 Mio €) 10 – 15 Mio € = (2x10 Mio €)

physical-chemical treatment 5 to 10 Mio € = (1x10 Mio €) 12 – 20 Mio € = (1x10 Mio €)

incineration plant 0 50 to 80 Mio € = (1x80 Mio €)

Cement industry, prepara-tion of secondary fuels

15 - 30 Mio € cement kiln ad-justments + 4 Mio € RDF preparation = (1x15 Mio €) + (1x4 Mio €)

0

hazardous waste landfill 5 Mio € landfill adjustment = (1x5 Mio €)

10 Mio € + 2 Mio € Stabilisa-tion platform = (1x10 Mio €) + (1x2 Mio €)

Total 59 Mio € 122 Mio €

Total investment volume in hazardous industrial waste management facilities is approxi-mately 181 Mio € within the next 10 to 15 years.

Additionally about 8 Mio € (3 OIL+1 ASB +2 WEEE+2 ELV) = in a short term and 19 Mio € (5 INF+3 OIL+1 ASB+5 WEEE+1 BAT+4 ELV) = in a medium term are related to the establishment of new infrastructure for specific waste streams like mentioned above where other financing mech-anisms might occur when collective schemes have been established.


Table 73: Short and medium term investment in special hazardous waste treatment faclities managed by col-

lection schemes.

Special waste stream Short term investment Medium term investment

Infectious waste 0 5 Mio €

sterilization via autoclave or incinerator

Waste oil 1,5 Mio € + storage = 3 Mio €

1,5 Mio € + storage = 3 Mio €

Asbestos contaminated C&D waste

storage compartment, 10.000 to 15.000 € per stor-age unit + landfilling 10 €/m³ to 25 €/m³ = 1 Mio €

storage compartment, 10.000 to 15.000 € per stor-age unit + landfilling 10 €/m³ to 25 €/m³ = 1 Mio €

WEEE Adjustment measures 2 Mio €

New facility 5 Mio €

Portable batteries 0 sorting facility <= 1 Mio €

ELV 2 Mio € for dismantling, shredding adjustments

4 Mio € for new dismantling, shredding facility

Total ~ 8 Mio € 19 Mio €

In accordance with the needed infrastructure to meet targets in integrated hazardous waste management, total estimated investment cost will amount to approximately 208 Mio €.

Remark 1 : Total costs for PCB elimination programs depend on future decisions concerning the stepwise replacement of contaminated PCB transformers. This is why these costs could not be considered here. These costs might have a significant influence on the total investment costs.

Remark 2: The same is for contaminated soils from future remediation programs. Implementation plan do not exist yet and so far future waste management costs could not be considered. Examples from other countries prove that such investment can be minimized by concentrating sev-eral of such hazardous waste management activities in central treatment and disposal facilities. As an example of the investment costs for a treatment and disposal center in Morocco has been presented above, where investment costs of 34 Mio € have been calculated for an integrated treatment and disposal center (without incineration unit). But such new sites demand long preparation phases for assessment procedures – often with un-predictable results. This is why another approach seems to be more promising: Integrating hazard-ous waste management units –storage, treatment and incineration facilities – into industrial com-plexes and process lines. This is a more decentralized approach with modular systems to be added with increasing demand and know-how. Permits for treatment and public acceptance usually are easier to be obtained. Knowledge about hazardous substances handling usually exists within the staff.


Corresponding to the “polluter-pays-principle”, both parts,- infrastructure for industrial, commer-cial and municipal hazardous waste and infrastructure for specific waste streams manage-ment - will be carried out through investments of the private sector, facilitated and supported by the use of available assets of the Fund, the Development Fund, and international funds and real-ized on the basis of permits for private waste management activities that will be defined after en-actment of Serbian regulations on manners and procedures of collection, transportation, treatment and disposal of such hazardous waste streams. For specific waste streams producers’ responsi-bility will be transposed by specific cost covering mechanisms that will be clarified in chapter 8.

7.3.3.2 Operational costs in Serbia

Operational costs grow evenly in accordance with the investment accumulation.


8 SOURCES AND AMOUNTS OF FINANCIAL FUNDS FOR REALISATION OF ALL WASTE MANAGEMENT MEASURES FOR HAZARDOUS WASTE

Principles guiding financial planning Compliance with the Waste requirements is the second most expensive sub-sector after Water and requires careful financial planning. In order to organize the financing process efficiently, several fi-nancing principles have to be respected: Concentrating the available resources on the most expensive sub-sectors

Meeting EU requirements for the lowest cost

Public funds are allocated for priority public infrastructure

Cooperation (regionalization) in order to reduce costs

Staged approach during implementation

Sharing IPA II funds among priority infrastructure needs

Reducing highest impacts on environment first

Absorbing the maximum environmental funds by co-financing

Making investments affordable

Long term planning to improve investment process

Active participation in project preparation.

This chapter shall estimate the principles that guide financial planning and the strategic approach to achieve the IHWMP objectives and targets. This chapter shall describe potential sources of financing the priority investments as well as the long-term investments stipulated for the period from 2019 on. In addition, in chapter 8, considera-tions are undertaken to cover possible deficits of the needed investments, to detect domestic sources of financing, and to give an overview of economic instruments that could enable coverage for the deficit in medium-term period. The chapter 8 contains an indicative financial plan. Financial aspects of the waste management system pertain to calculating predominantly invest-ment costs and investment costs return. Such detailed financial analysis requires: To provide a reliable financial plan for coverage of expenses in the period of project implementa-

tion;

To prove the availability of adequate financial sources for covering all further financial require-ments and liabilities;

To determine the level of tariffs required for the selected degree of refunding the financial sources through income from the project;

To prove the financial sustainability of the project as a whole.

By an insight into the estimations of expenses for harmonization of the national regulations of coun-tries in transition (Central and East Europe) with the EU regulations – it has been calculated that capital investments for the waste sector amounted to approximately 120 EUR/inhabitant. Some countries had extremely large investments, such as Slovenia with 600 EUR/inhabitant.


The estimation has been done based on the following approach: waste streams and composition have been estimated for existing information and preceding

studies and plans on specific waste streams for which the NHWMP stipulates a provision of waste management system and facilities (chapter 7.1. and 7.2).

for each waste stream, technical requirements needed to meet the objectives set in the legal framework, constitute the basis for calculation of costs.

systems, plants and equipment needed for fulfilling these technical requirements have been constitute another basis for the calculation of the costs

capital investments and operational costs pertaining to these systems and plants have been de-fined scope of the expected costs with regard to the estimated GDP in the observed period has been estimated

national and international financial sources that are potentially available to finance these in-vestments have been identified

the issue of coverage of resource deficit that are potentially available at local level and neces-sary investments has been considered

total investments needed for the Action Plan and strategic measures implementation by 2019 have been determined, as well as responsibilities to finance measures in private and public sector

indicative financial plan has been prepared using general assumptions about possible funding in-flows from different national and international sources

economic instruments that could mitigate unbalance between the investment costs and estimat-ed financial sources have been identified

necessary institutional resources for priority measures referred to in the Action Plan have been estimated

8.1 Estimated present waste management costs

The present unregulated and semi-regulated dumping and landfilling of all types of waste in Serbia, mainly in old landfills (which do not meet the standard in accordance with the already existing regu-lations) means that the present costs for hazardous waste management in Serbia are extremely low. Such low costs don’t create any incentive neither for compliance with the law nor for invest-ments into secure landfills and/or recycling installations. Future operational costs for hazardous waste will be decisively much higher. In accordance with the polluter pays principle, the costs for the management of hazardous wastes should be assigned solely to the waste generator. The current situation with mostly unregulated dumping has some fi-nancial benefit for the waste generator; however extensive costs for future remediation as well as social costs for waste caused illnesses are transferred to the public. This should be mentioned when describing present hazardous waste management costs in Serbia Another preliminary remark should be given: A sound management system for hazardous waste would benefit in two ways: 1. Such a system would achieve a true-cost pricing and assign the costs to the polluter, and 2. The separation of the hazardous waste streams is a pre-requisite for a recycling/recovery sys-

tem for non-hazardous waste streams. Such a recycling system would help to reduce resource consumption and can, when proper established, even gain a financial profit for the waste gen-erator.


Present costs for collection of hazardous waste from industry and commerce Few hazardous waste types like waste oil (25.000 t) of a certain quality (high calorific value) or lead acid-batteries (25.000 – 35.000 t) have a positive market value; therefore their collection system primarily is based on the economic value of the waste. Such waste streams are more or less com-pletely covered by the formal or informal waste management sector and are collected in any case to be sold to users. Compared to the profit, the collection costs of such waste streams are neglect-ed. No details are available about the collection of many other hazardous wastes from industry and commerce without a positive economic value; examples are acids, chemical waste, oil-contaminated solid or pasty waste, residues from thermal processes (EWC Group 10.02), waste water treatment sludge, (in total approx.. 10.000 – 15.000 t). Such industrial and commercial waste typically has been dumped in nearby dumpsites in Serbia. Transport costs from generators to nearby dumpsites are very low and might achieve 200 to 500 RSD/km and load, which is some 10.000 to 20.000 RSD/t and transfer. This depends on the type, the physical characteristics and of the hazard classes of waste (source: Serbian Association of Recyclers, email 2016 08 29). Present costs for collection of hazardous waste from the construction sector For asbestos containing waste, which constitutes a relevant hazardous waste stream from the con-struction sector, a collection system has not yet been established in Serbia. It is estimated that up to 45.000 t of asbestos containing wastes are generated per year. It can be assumed that the main amount of these unidentified asbestos wastes were included in C&D wastes and primarily landfilled (dumped) together with other C&D waste (for approx. 1.000 RSD/ton). Therefore big portion of as-bestos waste didn’t cause extra costs. For 2014 an amount of 111 t asbestos waste was notified to SEPA only, which caused additional costs for packaging and transport of some 13.000 RSD/ton (source: Serbian Waste Management Plan for Asbestos-containing Waste, 2012 11 draft). Present costs for collection of hazardous waste from the medical sector About 2.700 tons of hazardous Health Care Waste (HCW) have been moved from clinics to dis-posal sites; disposal technique was mainly treatment in autoclave and subsequent dumping in mu-nicipal dump sites. Costs are covered by generators (hospitals) and (at present) funded by bilateral technical and financial assistance projects. The specific technical equipment for secure transport and storage increase the specific collection costs to some 100.000 RSD/ton; treatment and dis-posal costs amount to some 150.000 RSD/ton. Total costs are some 250.000 RSD/ton (source: National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceu-tical Waste, 2013). Present costs for collection of hazardous waste from households Some hazardous wastes from households are collected in the context of special waste streams col-lection (e.g. WEEE, batteries, etc.). The costs for collection are borne by the producers (see be-low). For many other hazardous wastes from households, e.g. waste oil, medical waste, varnishes etc. no regular collection system has been established in Serbia. No specific costs are therefore gener-ated till now. Present costs for collection of hazardous waste streams covered by extended producer responsibil-ity systems No data on present costs are available, because, for the time being, there is no full extended re-sponsibility for WEEE, ELV and batteries in Serbia. Separate collection of WEEEby the official waste management sector is predominantly conducted by the operators of WEEE treatment plants themselves. Transport costs are negligible related to profit from selling ferrous and non-ferrous metal compartments.


No regular collection system for WEEE from households and small businesses (approximately 21.000 tons) exists. Such collection costs are integrated into the general waste disposal fees from municipalities. Municipalities do not provide collection facilities for separate collection of wastes from households. Retailers have the obligation to take back WEEE on a one-for-one basis; however, indication is given that the option is hardly used by end-users. No additional costs from such activities are to be applied. WEEE containing valuable material is furthermore collected by numerous actors of the informal waste collection sector, who provide pick-up services from households. Such costs cannot be cal-culated, neither. In Serbia there is no regular collection system for portable batteries and accumulators in place. Municipalities do not provide collection facilities for batteries and accumulators. Retailers do not take back batteries and accumulators. Additional costs are zero. The collection of automotive batteries, i.e. mainly lead-acid accumulators, is organized by the treatment plant operators in co-operation with “NGOs”. Compared to the profit, the collection costs of such waste streams are neglected. Serbia has not yet established a collection system for industrial batteries and accumulators. No additional costs incur. . It can be assumed, that ELV are often collected by informal collection activities, with the aim to sell spare parts and scrap metal for recycling. End-of-life vehicles might also be shipped abroad in-formally, or by private persons. Transport costs are extremely low (some 1.000 RSD per unit). These costs are negligible related to the profit from selling ferrous and non-ferrous metal compart-ments (90% of the weight of the car). Present costs for the export of hazardous waste Apart from the lead-acid batteries with positive market value (mentioned above), other hazardous waste has been exported to other countries in order to find cheaper or more appropriate treatment opportunities. About 3.600 tons of residues from industrial thermal processes have been disposed of abroad; prices are approximately 100 to 150 € per ton. Contaminated soils (2.600 tons) have been disposed of in neighboring countries due to proximity of appropriate (and cheap) disposal facilities behind the frontier; disposal prices are around 5 to 10 € per ton. Other industrial hazardous waste has been exported in the magnitude of 4.000 tons with the aim to find appropriate treatment and disposal opportunities. These wastes range from PCB containing transformers (118 tons)

and discarded components of WEEE dismantling processes like condensers and printed circuits (1.600 – 1.800 tons)

up to paints, varnishes, filter materials and absorbing materials (700 tons) that need incineration processes.

Disposal prices therefore range from 100 € for WEEE dismantling residues (source: Serbian Waste Management Plan for Electrical and Electronic Equipment and Waste Electrical and Electronic Equipment, draft 2012 08) to 1.000 € for PCB-transformers (source: Fact sheet analysis of differ-ent systems for management of POPs waste used in EU, June 2011) per ton.


Present costs for treatment of hazardous wastes No complete picture on the actual types of treated waste and the type of treatment conducted is available. Furthermore, indication is given, that a considerable part of the companies having a permit for treatment, disposal or storage of hazardous waste are not active at the moment. Present costs for physical-chemical treatment of hazardous waste The costs for the treatment of hazardous wastes in Serbian facilities for physical-chemical treat-ment are estimated to range approximately between 50 and 75 € per tonne Further treatment plants for hazardous waste Medical wastes are autoclaved and then landfilled in municipal waste dumps. Costs as reported in the National Plan for the Management of Waste Originating from Healthcare Facilities and Phar-maceutical Waste are around 2.000 €/tonne in Serbia. Costs for the cleaning und solidification of contaminated soils or for the treatment of asbestos wastes in Serbia are not available.

Present costs for incineration of hazardous waste Currently in the Republic of Serbia, three cement plants are operating, while two of them are con-ducting thermal treatment of different types of hazardous and non-hazardous waste, in accordance with the relevant waste management permits issued in accordance with the Law, while the third factory is in the procedure of obtaining the permit. In Serbia prices for thermal treatment in cement kilns range around 30 euros for high calorific liquid waste and from 300 euros upwards for liquid waste of low calorific value (SOURCE. Serbian cement Industry). Present costs for landfilling of hazardous waste The costs for the landiflling of hazardous wastes at Serbian landfills which currently have permits for the dispostal of hazardous wastes are estimated to range approximately between 10 and 25 € per tonne.


8.2 Options for the financing of the management of hazardous waste

8.2.1 Funding of activities and financing of investment measures

According to the draft amended National Waste Management Strategy, development of waste management infrastructure shall be based on solutions, which minimize investment and operational costs at the same time ensuring implementation of requirements. Targeted financial support from public funds will be provided for priority public infrastructure. Support for development of hazardous waste infrastructure from state resources shall be targeted for financing of priority hazardous waste management infrastructure establishing basic components in Serbia. It is foreseen that the waste management infrastructure shall be developed in stages starting with establishment of basic components of the hazardous waste management systems in first stage and adding additional components or developing more sophisticated solutions during next stages. In determining tariffs for waste management services, one should start from a decision about what degree of costs coverage through collection of charges from users should be applied: Full coverage of costs means that tariffs generate inflows that will cover all cash outflows and the remainder of debt at the end of the project cycle, and that will provide financial assets for the re-placement of facilities and equipment; Coverage of all cash outflows and the remainder of debt, but without providing assets for replace-ment investments at the end of the project cycle; this means that the replacement of capacities is financed from the capital market; Coverage of all cash outflows during the project period, but without providing assets for the re-mainder of debt and replacement investments; this means that the project is subsidized. It should be remembered that not only is it necessary to finance municipal and private waste man-agement infrastructure and sector functioning, but also technical assistance needed to provide support to organizational, technical and financial structures that are key to long-term sustainability of service provision. Technical assistance will be necessary to provide support to preparation of strategies and implementation plans of related EU-Directives. Preparation of documentation for ap-plying for project financing is a long-term process which can benefit decisively from experienced technical assistance and consultancy. In all EU MS “polluter pays” principle applies for hazardous waste management. Therefore costs of hazardous waste management are borne mainly by waste producer or the holder of the waste. Hazardous waste may only be passed to authorized facilities for recovery or disposal – responsibil-ity of generator or holder. Extended Producer Responsibility - waste management costs are borne by producer of a product or entity responsible for marketing of the product (WEEE, ELVs, batter-ies). This is true especially for industrial and for commercial hazardous waste generators/owners, hav-ing to cover the costs for the respective waste management measures according to the PPP. Con-trary to municipal waste management responsibility such waste generators pay only their individual costs on the basis of individual invoices from the waste treatment and disposal facility. These costs are usually calculated per tons and have a wide range depending on the market conditions between offer and demand of services

the relevant treatment and disposal technology applied and the state of the art of the facility

the complexity and hazardousness of the waste and the inherent pollutants to be destroyed.


Financing of the collection and treatment of special hazardous waste streams like WEEE, batteries and accumulators, ELV etc In most EU MS, producers and importers of electrical and electronic equipment have to finance the collection and treatment of WEEE und other specific waste streams. They are obliged to participate in collective schemes. They have to pay a fee to the collective scheme for any new EEE put on the market. The costs for the fee are in practice included in the retail prize. The collected fees are used to finance the collection, preparatory treatment and final recovery or disposal of WEEE and batter-ies/accumulators. Retailers are obliged to take back WEEE free of charge if new electrical or electronic equipment of the same type is bought. WEEE from private households may be delivered free of charge at desig-nated municipal collection points. Funding of innovative prevention and treatment of hazardous waste In many EU MS there exist Environmental Support Schemes for the continuous improvement of the environmental situation. The scheme shall influence local, regional and private decisions towards environmentally friendly and resource efficient investments. The schemes, however, also aim at in-creasing the economic and technical rate of innovation. One of the basic objectives of such schemes aims at minimizing air pollution, climate-related pollutants, noise (other than traffic noise) and waste. Funding in waste management is to promote the use of technologies for the recovery and the prevention of hazardous waste within business operations. Hazardous waste prevention measures usually receive the highest funding rates, followed by recovery measures. The budget of such Environmental Support Schemes (“Environmental Funds”) normally derives from the general national budget.

In Austria the following institutions are considered as key success factors for the funding of innova-tive prevention and treatment measures of hazardous waste: The establishment of a fund for the remediation of historical contaminated sites, financed

through fees on waste treatment used as an instrument to speed up the adaptation of waste management to the best available techniques and

Establishment of a public investment fund for co-financing of investments in waste management infrastructure. This fund is filled by the general Austrian budget.

Funding of illegal waste shipment The polluter-pay-principle is applicable in case of waste shipments, too. According to the Basel Convention, the notifier or the person who arranges the shipment of listed wastes is responsible al-so in case of illegal shipments or if a shipment cannot be finished as intended. In case that the responsible person is not known or cannot be identified within the legislative time limit for take-back measures, the competent authority has to act in place of the responsible person (notifier). In such cases, the financial responsibility can be assigned to the competent authority in the country of origin of waste. Nevertheless, there are cases where the source of the waste re-mains unclear. For such cases, the counties arranged a State Contract and assigned the financial responsibility to a central authority. In such cases the costs are split according to fixed individual rates. Financing of hazardous medical waste treatment and disposal in Serbia Cost recovery will take place on basis of the polluter pays principle. The costs for infectious waste management shall therefore be borne by the healthcare facility generating the waste. Since most healthcare facilities depend on the HIF for almost their entire budget, the Government will instruct the HIF to allocate funds for HCWM in all contracts they conclude with HCIs.


Since in the longer term, the financing of healthcare will be reorganized and the introduction of cap-itation and Diagnostics Related Groups are anticipated. With this reorganization, the need for fund-ing of HCWM will be taken into account and required funds will be integrated in future funding mechanisms. The generators of pharmaceutical waste are not only the healthcare institutions, in fact these are only small producers, but also pharmacies and households, expected to be the larger generators. The costs for the management of pharmaceutical waste from HCIs and pharmacies are to be cov-ered by these institutions. Household will have to cover the cost for the management of their waste. Since households already pay for waste collection to their local public utility companies, a small portion of this fee shall be allocated to pharmaceutical waste management. Where necessary, the fee payable to the public utility company will be increased. Funding of remediation of contaminated sites The remediation of contaminated sites is another special area that needs specific financial frame-work. In most of the EU MS, the public has to cover all costs in connection with the risk assess-ment and the remediation of historical contaminations (industries and dumpsites), where legal suc-cessors do not exist. Such investments are covered by special investment funds or loans from the capital market. This guarantees the long-term availability of financial resources for the purposes of remediation of contaminated sites.

8.2.2 Public and private sector financing of the hazardous waste infrastructure program

Like in many other MS, financial responsibility will depend on legal responsibility and so far develop differently for different waste streams: The public (republican, provincial and local) authorities have the prevailing responsibility for provi-sion of services in the area of municipal waste management, management of sludge from munici-pal WWTPs and medical waste management, and they will invest significantly into new systems and infrastructure for these waste streams management. It is expected that private sector gets an important role in the investments and provision of these services through private-public partnership arrangements, to which they can provide funds and op-erational knowledge and experience. It is expected that private sector will significantly participate in provision of capital and/or long-term commercial loans for waste streams which are primary responsibility of private sector. These streams include hazardous industrial waste, construction and demolition waste and waste streams related to certain products, including WEEE, ELV, packaging and spent batteries. Among private investors, there will probably be providers of waste management services and major industrial waste generators, as well as companies or organizations that were established in compli-ance with legal requirements or were established to meet obligations prescribed by law. Nowadays in EU MS, any investment decision to construct new hazardous waste treatment plants or to enlarge the treatment capacity depends on market prizes, on presently generated amounts of hazardous waste and on market assessment of future developments. In a developing waste management economy this might be different: Some 40 years ago in Vienna Austria, the first incineration plant for hazardous waste was constructed by the municipality of Vi-enna in order to provide adequate treatment capacity. Then, the market was not fully developed so involvement of the public sector was required. Other facilities in the 1980ies, like physical-chemical waste treatment plants were constructed by private companies, formerly involved in the business of fuel supply and waste oil management.


8.2.2.1 Available financial resources within the Republic of Serbia

Potential domestic sources of financing are as follows: Budget funds from national or regional governments, of local self-government and of public utility

companies (own funds);

Loans from national, regional and local commercial banks;

Investments from private capital into local PPP models.

The usual state contribution to the national and regional waste management systems in countries that have joined the European Union is in the range of 20 to 25% of the initial project investment. Ad 1: Budget funds of national or regional governments, of local self-governments and public utility companies (own funds) Capacities of local self-governments to finance infrastructural projects are low, and improvement is not expected in this short period of time. Belgrade municipalities are exemption: They are charac-terized by strong economic activities and stable revenue flows collected from construction fees and other sources, that smaller and poorer municipalities in Serbia do not have. Municipal bonds have been introduced recently as one of the options for municipality financing; however, they are only expected to achieve better position in financing. General financial state of Serbian municipalities suggests that it is not probable to be a sustainable source of financing of such infrastructural investments, except of few bigger municipalities with stronger financial capaci-ties. Ad 2: Loans from domestic commercial banks Commercial loans are potential source of financing for municipal and industrial infrastructural pro-jects, like hazardous waste management system, but restrictive conditions indicate that this is not a realistic source of financing for an investment program of such financial magnitude. Ad 3: Investment of capital into local Public-Private-Partnership (PPP-) models Investment of private capital is limited in Serbia, although PPP starts to appear as a solution for provision of municipal and industrial infrastructure, including waste management projects. Yet, it is probable that international waste management companies become the main investors in this area, if prospects appear favorable. Part of favorable conditions are good data, transparent legal provi-sions and open markets. As an example of public financing of waste management investments might be given the Polish “National Fund for Environmental Protection and Water Management”. It was established in 1989 and is the central pillar of the Polish system of financing environmental protection. The basis of its operation as a State legal person is the Act on Environmental Protection Law – it is a separate and independent entity supervised by the Minister of Environment. The National Fund carries out inde-pendent financial economy, acting pursuant to the Act of The Environmental Law and according to the ‘the polluter pays’ principle. The fund generates its income from: charges and fines for the use of the environment,

maintenance and concession charges,

energy sector charges,

sales of greenhouse gases emission units.


The National Fund ensures absorption of foreign funds allocated for the environmental protection, for example, from the Cohesion Fund, the European Regional Development Fund, the LIFE+ Pro-gram, the Norwegian Financial Mechanism and the European Economic Area Financial Mecha-nism. The National Fund offers its beneficiaries support in efficient and timely implementation of projects. Above all, it provides financial support to projects fulfilling environmental obligations imposed on Poland resulting from the European Union membership. The basis for accepting and examining applications for co-financing by the National Fund are priority programs. The programs specify principles for granting support and project selection criteria. In most programs continuous calls for applications are organized. The above mentioned system guarantees that the financing process is transparent, objective and impartial, based on the selection criteria established earlier. Through National Fund co-financing of waste management or waste prevention programs can be ensured. National Fund may co-finance investments in waste management infrastructure listed in investment plans which are part of regional waste management plans. Investments plans are pre-pared by regions and approved by the Minister of Environment. Financing of National Fund of En-vironmental Protection and Water Management refers to the following area of waste management: Undertakings linked with waste management, waste prevention and education

Development of national waste data base

Treatment of waste from illegal shipments

Training programs of enforcers involved in control of waste shipments (customs, border police, environmental inspectors, traffic inspectors, police and prosecutors)

Treatment of waste from accidents

Analysis of waste performed by Environmental Inspection

Remediation of „historical” soil contamination

Other areas of relevance are: Water protection

Air protection and climate change

Nature protection

Monitoring of the state of environment

Ecological education

Functioning of EMAS

SEVESO accidents and mining damage reparations.

The National Fund also supports activities undertaken by the Minister for the Environment in ful-filling international obligations of Poland under multilateral environmental agreements, for example, the Climate Convention, the Convention on Biological Diversity or Basel Convention on trans-boundary movement of hazardous waste and its disposal.

8.2.2.2 Reduction measures for estimated financial deficit

It is evident that domestic capital for financing of public or private sector in the area of municipal and hazardous waste management systems and facilities in Serbia is insufficient, and that deficit between the necessary investments and domestic financial sources is quite high. It would be unre-alistic to expect that such deficit will be covered to great extent in the period up to 2019 and later on.


Therefore, further chapters will explore the possibilities of economic instruments to cover the deficit in the years to come. Key factors for financial sustainability of municipal (and private) waste man-agement services will be the capacity to generate reliable and foreseeable inflows and

the ability to mobilize external sources of financing.

A clear and unambiguous national policy for cost coverage and tariffs that pertain to waste is need-ed. Introduction of waste disposal fees, as well as additional charges for waste generators and producers, are mechanisms to generate additional revenues to finance these infrastructural activi-ties. Measures like these are expected to reduce deficit in a medium-term run. Yet, in short-term run, it will be necessary to count on international (public) sources of financing as the main tool to cover municipal (and private) funding deficits. Additionally, foreign private sources must be available to cover financial deficits related to private sector investments in hazardous waste management infrastructure. In both cases – public and private foreign sources of financing – it will depend on the credibility, in-cluding the reliability of inflows within the projects if such funds are made available.

8.2.2.3 Potential international sources of financing to cover the deficit

At the beginning of future (municipal and) hazardous waste management activities the needed in-vestment and the expected deficit will be as high that foreign financial sources will play an im-portant role in providing sufficient capital to co-finance such waste management infrastructure. Potential international sources of financing are the following: grants from the European Union Instrument for Pre-Accession Assistance (IPA);

bilateral grants and long-term loans from other countries;

long-term loans from international financial institutions (IFI);

public-private partnership arrangements (PPP);

private investors’ capital;

long-term loan capital from commercial financial institutions.

Such financial aid from foreign sources is also available for project preparation and application pur-poses, such as financial and technical assistance for feasibility studies, cost-benefit analysis and project application. Suitable potential sources for different steps of project realization have to be analyzed in details during the project preparation period. Ad 1: The European Union Instrument for Pre-Accession Assistance (IPA) It is expected that grants obtained through the European Union Instrument for Pre- Accession As-sistance (IPA) shall be the main source of financing for the proposed integrated hazardous waste management system with its related facilities. The EU grants are the main financing source of projects in the area of municipal and hazardous waste in many countries that have recently become EU MS. Availability of such funds is justified due to the fact that progressive harmonization with the EU requirements of hazardous waste man-agement diminishes the cost and price differential between MS which – again – diminishes the ille-gal or legal incentive of transnational shipment of waste.


Such grants avoid social inconveniences of sudden increase of waste management costs and fees that certain parts of the society (citizens, commerce and industry) cannot afford at once. Grants enable fees to stay below the level of affordability and under the level that would be needed for full cost coverage. For social acceptability and for future sustainability of such innovation programs, considerations about the national cost recovery policy, about tariff and affordability policies, are of key importance - regardless whether the assistance comes from the EU grants or from PPP model. Ad 2: Bilateral grants and credit capital Bilateral assistance in the form of grants for financial and technical assistance and for financing in-vestments is obtained through programs established by national agencies in many European coun-tries. Donors usually ask for financial obligations from the national project partner, e.g. in terms of co-financing through national funds. Bilateral grants may play an important role in mobilizing addi-tional sources of financing. Once more, additional financing from bilateral grants may reduce social pressure of increasing fees. It is therefore suggested to explore possibilities for obtaining bilateral technical and financial assistance from MS national agencies. Ad 3: Loans from international financial institutions (IFI) Loans from international financial institutions are an important potential source of co- financing of municipal and hazardous waste management facilities. International financial institutions provide also technical and financial assistance for such infrastructural projects. Financial assistance is usu-ally provided through soft loans, which means that conditions for loan return are more favourable than the conditions in case of commercial loans. Project developers face strict requirements for loan granting, including technical, economic, social and ecological criteria that must be fulfilled within the project. Financial status, capacities and cred-iting capacities of user’s organization is closely examined. The most important international finan-cial institutions (IFI) in Europe are European Investment Bank (EIB), European Bank for Recon-struction and Development (EBRD) and the World Bank (WB). Ad 4: Public – Private Partnership Based on the “polluter-pays-principle”, hazardous waste management is a priori a matter of private engagement. Therefore it is necessary to encourage - and prepare the organizational and financial prerequisites of greater participation of the private sector in hazardous waste management system in the Republic of Serbia. This means that industrial and commercial waste management systems and associated facilities, as well as those for specific waste streams (batteries, WEEE, ELV etc.) , are financed primarily from private sector funds. This is true – for some extent – also for municipal waste management systems and facilities: Pub-lic-Private-Partnership (PPP)- arrangements are emerging in the Republic of Serbia too as a ap-propriate tool for financing and operating municipal waste management infrastructure. Lack of fi-nancial resources for infrastructure projects force municipalities to such financing and operating models. Yet, the range of such contracts will greatly depend on the national and regional policy concerning PPP model application. Ad 5: International capital (private investments) Private sectors investors usually finance investments through a combination of own capital and loans. This is the model that usually is applied by internationally acting waste management opera-tors, big national waste generators and national companies / organizations that have been estab-lished for the management of specific waste streams (ELV, batteries, WEEE etc.). Ad 6: Long-term loan capital from commercial financial institutions Long-term loans from commercial financial institutions are a potential source for financing optimiza-tion of private investments in waste management purposes.


8.2.3 Indicative financial plan

It has been estimated that investment needs for hazardous waste management in Serbia amount to a total of approx. 208 million €. Related to the estimated amount of total investment in municipal waste management in the order of 958 Mio € (source: waste strategy), this is a rather limited in-vestment volume. The investments into such systems and facilities will most probably be financed through a combina-tion of the following financial resources: Capital grants from the former Serbian Environmental Protection Fund (EPF);

Funds for the private sector realizing such projects within the PPP model application;

Capital grants through European Pre-Accession Assistance (EU IPA);

Funds from national or regional governments, from local self-governments and public utility companies (own funds)

Long-term loans from international financial institutions (IFI);

Capital grants from bilateral donors.

At this moment it is not possible to specify in detail the contribution of these funds. But other than in municipal waste management and generally spoken, it is expected that an essential part of invest-ment in hazardous waste management systems and facilities, has to be undertaken by the private sector from its own capital and/or long-term commercial loans (including national industry, interna-tional and national operators and national private institutions/organizations in the context of special waste stream management ( ELV, WEEE, batteries etc.). It is expected, that IPA and later Cohesion and other EU funds will contribute the largest part of public funds for environmental investment in Serbia. Based on the experience of other countries, now new Member States, assumptions can be made concerning the contribution of national and in-ternational funds, of private and public financing: About 90% of total EU funds for environment are directed to finance infrastructure investment

70% of total investment funds will be allocated for water sub-sector projects

30% of total investment funds will be allocated for waste management sub-sector

Co-financing from national resources shall be at least 30%.

This means, generally 70% of financing is IPA and other international support funds and 30% is na-tional co-financing, mostly from private sector. Under such assumptions the total funds for waste sector may be expected as presented in the table 9.1 of the Serbian WM Strategy. Table 74: Forecast of funds for waste sector financing.

Financing peri-od 1 2014-2020



Total in Mio €

Water and waste manage-ment infrastructure financ-ing EU

144 1.288 1.288 2.719

National co-financing 30% 62 552 552 1.165 Total funds 206 1.839 1.839 3.884 30% of funds for waste management

62 552 552 1165


This means, that most of investment into hazardous waste management infrastructure can be completed during next two financing periods (up to 2027). Based on the experience of other coun-tries concerning the available derogations and transition periods for heavy investment directives this time laps till 2027 is to be used for the whole of the designed investment program.

8.2.3.1 Instruments to cover financial deficit

There exist a variety of approved economic instruments that may contribute to decrease the ex-pected financial deficit resulting from necessary investments into hazardous waste management systems and facilities. These instruments include: Cost recovery policy and

Landfilling fees.

Capacity building programs in the national and regional public institutions responsible for hazard-ous waste management can also help to identify, explore and monitor potential financing resources in order to decrease the financial deficit in this sector. Ad 1: Cost recovery and tariff policy Financing of investments into hazardous waste management systems in an effective way is only possible, if reliable and foreseeable cash flows are generated; such cash flow must be sufficient for: loan servicing and repay;

coverage of regular expenses during operation of the facility, including expenses for replace-ment of assets;

coverage of costs that are devoted to the plant shutting down,

coverage of costs to recover investment and to maintain investment, and

in the case of private investors - generation of profit which recompenses opportunity costs of the investor and business risks.

Concerning financial responsibility of the waste generator, European policy and legislation are clear in this context: Waste generators shall pay (through user charges) for the whole amount of services and plants that are needed for management of their waste in environmentally adequate manner. The collection system for such user charges, - it’s level, it’s transparency, it’s affordability etc - is of key importance for the acceptability and for the effectiveness of the financing system; otherwise severe budget deficit and overdependence on public budgets impend. Prices for use of such hazardous waste management services and facilities must reflect the long-term costs of such activities. In order not to overstress the acceptability of such new cost covering systems, such policy must be introduced gradually, enabling the users to take into account and to adapt to higher prices for use of public and private facilities and services that commonly are much more expensive than previous solutions. Grants and subsidies may help to facilitate transition to full cost recovery prices. Generally spoken, all new EU member states adopted specific procedures for finding affordable prices for waste management services. Often, an upper limit for the share from a household in-come to be allocated for waste management services was defined. The definition of this “affordabil-ity limit” varies from country to country.


For example, waste tariffs in Czech Republic for municipal waste services are in the range of 0.7% of average household income. In Romania, tariffs for waste do not exceed 1.5% of poorest house-hold income, but they allow for introducing more complex tariff structures based on affordability. Waste tariffs for hazardous waste management services are often oriented at the means of sales / turnover of a certain industrial sector typically benefitting of such treatment and disposal services. As an example the financing and cost recovery decisions of the Tunisian government concerning the pricing hazardous waste management system may be quoted: To achieve economically reasonable waste management costs for the producers the Tunisian gov-ernment decided as a start to partition the operational costs in two halfs: The Tunisian government bears the fix costs and The producers have to support the variable costs of treatment (depending of type and quantity of waste and type of treatment). On this basis the responsable waste management agency (ANGed) established a list of some 30 specific prices. Applying this cost sharing model, ANGed has calculated the following means of treatment costs to be charged to the industry (see the following table). Compared to the “zero costs” of actual disposal practice the additional charge for Tunisian industry seemed to be econom-ically reasonable – at least at the beginning. ANGed compared these treatment and disposal costs with the total costs of production of all 10 main industrial sectors and calculated a ratio of 0,002% (shoe and leather industry) to 0,183% (metal industry) of the production costs. This was judged to be tolerable for Tunisian industry. Table 75: Disposal costs to be charged to Tunisian industry compared to European disposal costs (2008).

Type of treatment France €/t Germany €/t Tunisia €/t Hazardous waste landfill 50-140 50-140 10 Stabilisation/solidification 120 80-100 25 Physical- chemical treatment 175-350 60-450 15-30 Incineration 300-800 200-1000 none

Certain rules related to affordability aspects when asking for EU grants might be given in the text below: Use of the EU grants maintaining tariffs at lower level than full cost recovery level is not in compli-ance with the requirements for full cost recovery that are usually related to EU PPP-models. Introduction of affordability limits for hazardous waste management tariffs recognizes that full price for improved services is not affordable for all users. This, in fact, can serve as justification for appli-cation of EU grants. Different tariffs according to affordability level of different user groups (small commercial enterpris-es, monopolists, municipalities, foreign users) should be introduced. Otherwise, the affordability limit has a subsidizing effect to those who can pay higher fees. This would result in insufficient money inflow and - in consequence - higher level of the EU grants, needed for financing the haz-ardous waste management projects. Taking into account the high competition when applying for limited financial EU funds, problems in financing the operation are programmed. Users should pay different tariffs up to the full cost recovery level in accordance with their afforda-bility level. This implies rough knowledge about the income level or turnover of industrial and other economic sectors, of single enterprises and of households. Tariffs progressively should increase until they reach a level that reflects total costs of operation and maintenance. This may involve different methods for collection of fees. Bearing in mind that selection of cost recovery method for hazardous waste management services is a complex issue, it is necessary to explore and implement pilot test with the parties concerned before making a final decision.


Significant discrepancies in average income exist between different regions and sometimes within a region. Such social-economic conditions in the regions must be addressed in order to be able to generate a sustainable system of fees. As for PPP arrangements, private investors need full operational cost recovery (including deprecia-tion), and want that return to the invested capital be proportional to business risk. Private investors expect certain level of reliability of cash flow estimations. This needs careful, reliable and transpar-ent public and private planning. Due to the fact that PPP arrangements are rarely supported by grants, long-term sustainability of private investment requires tariffs that must ensure complete costs recovery. Taking into account that it is difficult to combine the EU grants with PPP arrangements, the most efficient approach would be to finance some projects from the EU funds (e.g. hazardous waste treatment plant and landfill), while others would be financed from private sector funds (e.g. waste derived fuel produc-tion and incineration, dismantling facilities, sorting plants). Ad 2: Landfilling and other fees Another fiscal instrument of service charging is a hazardous waste landfill tax. Namely, all waste that goes to a hazardous waste landfill should be taxable and the tax should be paid – directly or indirectly - by the waste generators. In case of public financing of hazardous waste landfilling, prin-ciples from municipal waste landfilling tariff system could be applied: As an example, such a system of differentiated, growing fees had been developed in Czech and Slovakia in the nineties. Landfill fees are basically composed of two parts: Basic tariff per ton of waste landfilled in licensed landfills (A-tariff), and

Additional fee if landfilling takes place in licensed landfill cells that are not harmonized with tech-nical requirements of new landfills (B-tariff).

B tariff is a tool to consider external (ecological) costs imposed to the society by the facilities that are not compliant with the requirements of hazardous waste landfills in Serbia. In this way, the dis-crepancy between higher operational costs of compliant facilities and lower operational costs of non-compliant facilities would be equalized. Such landfilling fees can also stimulate waste generators to minimize hazardous waste. In many cases, this is possible with little investment if external constraints affect the willingness of genera-tors. The beneficiary of such landfilling fees can be the municipality, the regional government or the Environmental Fund, collecting the fees for grants for suitable public waste management projects. The basic structure of the fee will most commonly be: Base line landfill tax for all types of hazardous waste and additional fee for disposal at other lo-

cations that are not compliant with the requirements and technical regulations of the European Union and the country itself.

Further differentiation according to hazardousness of waste.

Annual adaption in accordance with legally binding and adequately published rules, until pre-defined final level is reached.

Introduction of such a system has proved to be very efficient in other countries, both in terms of generation of revenues and of introducing substantial changes in waste generators behavior. Intro-duction of landfill fees in Czech Republic and Slovakia in 1992 helped to facilitate the closure of numerous uncontrolled dumpsites and to promote the nationwide network of sanitary landfills. In such cases, the landfill fee must help to divert the waste flow to such compliant facilities and so far help private sector operators of such landfills to work economically successful.


Role of Ministry Ministry should review and expand the role and expenditures dedicated to financing the waste management system in compliance with the Strategy objectives and future requirements of the EU. Significant role must be stipulated to the development of economic instruments, especially in order to identify and mobilize external grants from bilateral donors, to develop cost recovery policy, tariffs for waste management services and landfill tax, and to provide assistance related to the higher participation of private sector in provision of infrastruc-ture for hazardous waste management.

8.2.3.2 Conclusion on financing

Based on the experience gained in Austria, Germany and Poland with establishing hazardous waste management systems compliant with EU requirements following recommendations can be provided:

1. The Republic of Serbia should stick to its objective to fully transpose EU waste management legislation into Serbian law till then end of 2018. In order to comply with EU waste legislation major investments and a sound financial basis for these investments and for operating a com-pliant waste management system will be required.

2. It is recommended to improve the current implementation of the polluter-pays-principle in Serbia: e.g to reduce the administrative burden for the companies which require subsidies from the Environment Ministry (Fund).

3. An Environmental Protection Fund (EPF) should be established as a separate non-profit organization under supervision of the MoE for: co-financing the infrastructure for hazardous waste management (co-)financing the remediation of historically contaminated sites (co-)financing the disposal/treatment of historical hazardous waste stock-piles.

Apart from “fees for products put on the market”, the income of the EPF could be secured by imposing: “fees on the use of the environment” (example from Poland),

“fees on waste disposal” (example from Austria) or

by allocating an adequate budget post from the general budget (example from Germany).

Fees and fines for infringements against Environmental law should also be paid to the EPF. The instrument of extended producer responsibility should be realized to its full potential: Collective schemes should be introduced for all waste types for which corresponding EU require-ments exist (WEEE, batteries, ELV) as already implemented for PPWD. Within the legal framework the responsibilities have to be clearly defined for producers and the other stakeholders (collective schemes, municipalities, public utility companies etc.). The mechanism of achieving the collection, recovery and recycling targets (individually or by collective schemes) including monitoring process shall be defined. Adequate administrative capacity for enforcement needs to be installed. The fee system which is in place in Serbia should be adapted to avoid a double paying for products covered by collective schemes.


Necessary steps to assure competition among the collective schemes and to assure a high effi-ciency and effectiveness of these schemes should be taken: a legal framework should be set-up which allows the competent authority: to issue a permit for the “new” collective schemes. The permit should contain the minimum re-

quirements for operating (e.g: upper limits for self-administrative cost, targets with regard to collection, recycling, recovery rates referring to the contracted quantities).

to ensure that the collective schemes fulfill their responsibilities according to the market share, and that the total area of Serbia is covered by their services. This responsibility could be dele-gated to a “clearing house”.

Another aspect of making enforcement more effective, is to create a system of administrative fining (for misdemeanors); thus, cases of misdemeanors should no longer go to the criminal court. The competent authority for imposing fines could be the inspectorate. An instance for appeals would be needed. Fines must be executed quickly, and must be sufficiently high to have a deterring effect. The revenues from the fines should be used for environmental purposes.


8.3 Financing and measures for establishing the waste management system

Costs expressed at annual level Implementation costs for the hazardous waste management infrastructure may be placed in the context by making comparison with the estimated GDP over the implementation period. There are two approaches: Comparison between the sum of overall annual capital investments and operational costs with

the estimated GDP, and

Conversion of cumulative capital expenditures into capital costs at annual basis and comparison between total annual costs (operational costs plus capital costs at annual basis) with GDP.

Total costs at annual level compared with the estimated GDP Costs calculated at annual base are composed of annual operational costs plus estimates of costs for utilization of assets to be used throughout the year. This is the indicator of costs for utilisation of national resources throughout the year, and it can be calculated as a percentage of the estimated GDP. It provides for costs estimates for resources that pertain to waste management programme, costs for economy that are expected to continue in the future.


9 DETERMINATION OF OBJECTIVES

9.1 Key principles in hazardous waste management

The key principles that must be taken into consideration when establishing and implementing the waste management plans are as follows: Sustainable development principle;

Principle of hierarchy of measures in waste management;

Precautionary principle;

Principle of vicinity and regional approach in waste management;

Principle of selection of the most favourable option for the environment;

“Polluter pays” principle;

Extended producer responsibility

Sustainable development principle The definition of sustainable development postulates the fulfilment of needs of today’s genera-tion without threatening the oportunity of future generations to meet their needs. The principle promotes an equal development with the economic growth ensuring the reduction of poverty, fair distribution of wealth, improvement of quality of life and reducing the level of pollution to the level of capacities of t h e environment, prevention of future pollution and biodiversity conserva-tion. This sustainable waste management means more efficient exploitation of resources, reduc-tion of quantity of generated waste, and once the waste has been generated, its handling in such a manner to contribute to the objectives of a sustainable development. Principle of hierarchy of measures in waste management The hierarchy in waste management means the following order of priorities in the waste man-agement practice: Prevention: Qualitative waste prevention (reduction of hazardous characteristics of waste, pol-

lutant elimination, pollutant substitution), quantitative waste prevention (reduction of waste gen-eration), Re-use (“Second Hand”, reusable packaging), Reduction of the harmful effects of waste on health and environment;

Preparing for Re-use: Cleaning of for example used clothing, Functional testing of for example Electrical and Electronic devices or components thereof;

Recycling: Reprocessing of waste materials into products, materials or substances whether for the original or other purposes (“bottle to bottle”, “Metal to Metal”, composting…)

Other Recovery: Utilisation of waste values for other purposes (Backfilling, Recultivation, Ener-gy recovery, other energectic or chemical utilisation

Disposal: Incineration without energy recovery, landfilling.

Precautionary principle The precautionary principle means that “in case there is a possibility of a serious and reversi-ble damage, absence of full scientific reliability may not be the reason for not taking measures for preventing the degradation of environment”. Each activity must be planned and implemented in such a manner so as to cause the least possible change of the environment. In case of potential and significant impacts on environment, preventive activities should be taken, while application of environmental impact assessment instruments should be particularly sup-ported.


Principle of vicinity and regional approach in waste management The waste is treated or disposed of in places as close to its generation as possible, and/or in the region in which it has been generated so that unfavourable environmental consequences during transportation could be avoided and local responsibility is increased. The selection of the site for the plant for the treatment and disposal of waste will be carried out depending on local conditions and circumstances, type of waste, its volume, manner of transportation, economic a n d social viability, as well as on potential environmental impact. Regional waste management is ensured by development and implementation of regional plans based on the European legislation and national policy. Principle of selection of the most favourable option for the environment The choice of the most favourable option for the environment is a systematic approach which comprizes scientific comparative environmental protection and conservation reflections that ac-companie the decision-making process . The comparition of the environmental impact oft he dif-ferent options determines the option that comprizes the highest benefit and the least harm for the whole environment, combinedwith acceptable costs and profitability, both in a long-term and in a short-term run. “Polluter pays” principle One of the most important principles is the financially sustainable activity of waste management based on the “polluter pays” principle. The polluters must bear full costs of the consequences of their activities. The costs of generation, treatment and disposal of waste must be included in the price of a product. The principle of full costs recovery for the services of collection and disposing of waste should be applied, as well as the introduction of f inanc ia l stimulation instruments for re- use and re-cycling of waste. The charging should be carried out according to the quantity of generated waste and the type of intended treatment relative to its position in the hierarchie of waste treatment options in order to create a motivation for reducing the volume of waste at the source and for recycling. The Ministry and other competent authorities should also apply the principle of waste reduction when granting approvals in relation to the EIA and IPPC permitting. Extended producer responsibility. Producers, importers, distributors and sellers of products influencing the increase of waste volume are responsible for the waste generated as a result of their activities. The producer bears the greatest responsibility because he influences the composition and the characteristics of a product and its packaging material. The producer is obliged to take care of the generation of waste, development of recyclable products, development of the market for re-use and recycling of their products. This practically means that the producer is responsible for their products till the end of product life cycle, or "from cradle to grave", and that they can fulfill their obligations either individually or collectively (inclusion into a collective scheme).

Additional principles applied in this Plan as well in the Serbian Waste Management Strategy are as follows: Meeting EU waste management standards at lowest costs Development of waste management infrastructure shall be based on solutions, which minimize in-vestment and operational costs at the same time ensuring progressive implementation of require-ments.


Targeted financial support from public funds for priority public infrastructure Support for development of waste infrastructure from state resources shall be targeted for financing of priority waste management infrastructure establishing basic components and for supporting and ensuring private sector engagement in waste management activities. Staged approach during implementation Waste management infrastructure shall be developed in stages starting with establishment of basic components of the integrated waste management infrastructure and adding additional components or developing more sophisticated solutions during next stages when knowledge about generated waste and collection rates increase. 9.2 Strategic objectives regarding hazardous industrial and commercial

waste management

Strategic objectives as laid down in the Serbian Waste Management Strategy are as follows:

Harmonization of national regulations in the field of waste management with EU leg-islation; strengthening administrative capacities; adopting an IHWMP. The Law on Waste Management and all by-laws are in a process of harmonization with EU regulations; for achieving this, administrative capacities have to b e promoted , especially w i th in the institutions and organisations in charge of planning, permitting, controlling and monitoring Serbian waste streams; therefore and for preparing adequate investment decisions a National Integrated Hazardous Waste Management Plan (IHWMP) has to be adopted.

Establishment of Hazardous Waste Management responsibilities within the regions It is necessary to support inter-municipal agreements on joint waste management in the regions and to promote regional responsibility for hazardous waste management as one essential tool for economic growth. Local and regional institutions in charge of waste management should be instructed in hazardous waste managment needs and oppor tu-n i t ies ; capacity building must go on; regional hazardous waste management plans can be a tool to raise public responsibilty and awareness about the necessity and conditions of establishing a nationwide integrated hazardous waste management system.

Establishment of an integrated management system for hazardous waste in Serbia;

It is necessary to introduce separate collection and treatment of hazardous waste streams generated from Serbian households, commerce and from industry; therefore professional and institutional capacities for hazardous waste management have tob e strengthened; lo-cal and regional storage capacities for hazardous waste have to b e foreseen all over Serbia; construction of a plant for physical- chemical treatment of industrial hazardous waste and for the preparation of waste derived fuels has to be initiated; capacities for haz-ardous waste landfilling have to b e increaesed; exportation of organic hazardous waste to suitable facilities abroad is an intermediate solution only; in the longterm period capacities for incineration of organic industrial and medical waste should be created.

Creation of a management system for special waste streams with hazardous com-ponents like used batteries and accumulators, waste oil, end-of-lige-vehicles (ELV), waste from electric and electronic devices (WEEE) etc. This system aims at meeting EU minimum requirements for WEEE ( 4 kg per capita sepa-rately collected waste from households by 2019) and of batteries and accumulator (45 % by 2016). It is necessary to establish recycling yards for non-hazaroud (paper, glass, plastic, cans) ans hazardous waste from households and commerce (WEEE, batteries and accumulators, waste oil etc.) in all municipalities; technical and economical instruments shall be introduced that will encourage re- use and recycling of waste material, and stimu-late appropriate infrastructure;


Establishment of a waste management system for medical and pharmaceutical waste; It is necessary to develop the national program for medical waste management further; waste management plans in all health care institutions and veterinary organisations are important tools for creating more respoinsibility and security within this system. Needed in-frastructure for medical waste treatment including thermal treatment capacities should be developped further.;

Development of a system for reduction of industrial hazardous waste implementing help desks and instruments to advise about cost reduction, material saving and re-cycling oportunities in industrial processes; Consulting industry and institutions should be enabled to advise industry about cost reduc-tion through material saving and recycling within industrial processes; in many MS such consulting schemes and public financial encouraging systems have been developped and run since decades; these experiences should be transferred to Serbia.

Promotion of material re- use of hazardous waste and of use as an alternative

source of energy in conformity with the waste hierarchy principle; For energetic use, cement factories, forges, thermal power stations and other heating plants are favourite partners for such projects; for material re-use, Serbian industry should analyze its industrial processes for appropriate recycling options. In both cases pre-treatment facilities are necessary elements of the solution. Therefore, itis necessary to prepare the technical standards, improve existing capacities and technologies; existing ca-pacities and permits in cement kilns should be used and developped progressively; new capacities in industry should be established.

Allocation of hazardous waste landfilling capacities; rehabilitation of existing dumps with hazardous waste that presents the highest risk for the environment, elimination of "black spots" that have been historically contaminated by hazardous waste. It is necessary to increase the capacity of hazardous waste landfilling eigther by new haz-ardous waste landfill sites or by using and enlarging existing capacities and permits for landfilling hazardous waste. Search procedure for suitable locations for future hazardous waste landfills should be initiated; hot spots and priority location of contaminated dumps and industrial sites should be closed, remediated and/ormonitored.

Set up a hazardous waste management system for different hazardous waste streams in order to facilitate investment decisions. It can be set up most efficiently in a Public Private Partnership with related industrial and commercial sectors. It requires a distinct legal framework as well as private investments in-to infrastructure. Investors need reliable data on predicted waste generation in order to ad-just their investments. A forecast of the yearly amount of important hazardous waste streams to be disposed off during the next 5 to 10 years would be preferable. From 2010 on waste owners have been requested to report to SEPA the amount and nature of the hazardous wastes produced; so, during the next years more and more reliable data on hazardous waste generation will be available for such investment planning.


9.3 Overall objectives regarding waste prevention of hazardous waste

Following objectives on the prevention of hazardous waste should be part of an overall national waste prevention programme. Responsibility for such an initiative should be within the ministries (MAEP, Ministry of Industry), the associations of the industrial sector and the individual members of the industrial sector themselves. Introduce the life-cycle aspect into Serbian industrial goods production processes to promote

prevention of hazardous waste by considering all levels of the life cycle of products from de-sign, through construction and use, to final dismantling, reuse and disposal. This is especially suitable for special hazardous waste streams like batteries and accumulators, electrical and electronical devices, vehicles and oil products. Involvement of product designers, construction engineers recycling specialists is crucial for success. In order to promote prevention of haz-ardous waste in the future, the following measures should be considered within the product design: - low-waste construction; - extending the useful life of products; - avoiding the use of hazardous substances in products; - selective, recovery-oriented de-composition and dismantling and - environmentally sound recycling technologies.

Introduce measures to collect and keep records of information on product composition and material used for the products; establishing and keeping available documents concerning se-lective de-construction, dismantling and recyclability.

Introduce and establish measures to force sustainable product design. This might be done e.g. by introducing standards for sustainable product design and construction; such standards give a guideline to consider general environmental aspects for the construction of new products.

Additional measures could comprise: Introducing the aspect on “low-waste construction” to higher technical education, with special

courses within relevant studies (e.g. mechanical engineering) and continuous training for product designers and construction engineers;

Introducing the aspect of sustainability of products when issuing permits for the import of products or permits for production facilities;

Establishing the consideration of sustainability of products as pre-condition when industry de-mands public financial subsidies.

The proposed objectives should be supported by the establishment of standards and guidelines. Working Groups on Ministry Level and Association Level might be a proper instrument to further elaborate and apply the described objectives. 9.4 Overall objectives regarding the collection of hazardous waste

Coverage of formal hazardous waste collection must achieve 100% within few years. Serbian waste statistics implicate that informal sector still plays an important role in some sectors of haz-ardous waste management. The overall goal of Serbia should be to strengthen the institutions, authorities in charge and private waste management services for more efficient hazardous waste documentation, control and operation. Regularly updated hazardous waste management plans can help private investors to engage in hazardous waste management sector. Spatial plans should identify the sites appropr ia te for hazardous waste management plants; voluntary agreements with institutions of the private sector should define goals for hazardous waste separation, collection and treatment in relevant industrial sec-tors; individual financial and administrative assistance from public entities should provoke necessary in-vestments in hazardous waste management facilities.


Development of public awareness and education of staff remains a permanent concern on all levels. Correct labelling and packaging of hazardous waste is an important part of such waste management activities. It enables appropriate and safe transport in bigger units and prevents acci-dents caused by inappropriate mixing of smaller units. Small quantities of wrongly identified haz-ardous substances (e.g. PCB oil) mixed with other fractions (e.g. motor oils) can deteriorate the re-cycling of such transport units and generate high disposal costs. In order to achieve the objectives of Waste Framework Directive, Serbia should plan source sepa-ration of hazardous waste in all commercial and industrial facilities. This is necessary in order to fa-cilitate or even enable recycling of non-hazardous waste fractions and to safeguard the Serbian environment from unintended pollution through unappropriate or even illegal hazardous waste dis-posal. Such forced hazardous waste separation at source facilitates as well economic sustainability of private hazardous waste collection schemes. Local self- government units should be focused on the organisation of primary separation in households and primary collection, segregation, labelling and packaging in municipal recycling ar-eas. Doing so, private hazardous waste collection services are able to transport such waste into reginal storage units or directly in appropriate treatment facilities. Separate collection needs storage facilities and appropriate final treatment and disposal capacities. Export of hazardous waste fractions which do not find appropriate treatment within Serbia is an in-termediate solution only. On a mid-term run Serbia should find suitable solutions for all types of hazardous waste generated in the country. In both cases state-of-the-art storage facilities are in-dispensable elements oft he management concept. They should be driven by private treatment plant operators or industrial facilities with corresponding experience in hazardous substance han-dling. 9.5 Objectives regarding the integrated management (collection, reuse,

recycling, energetic recovery, treatment, and disposal) of hazardous waste

The establishment of appropriate capacities for hazardous waste management in Serbia needs complete and confidential data. Such data comprise quantities of hazardous waste generated on the annual basis and regularly updated data on available waste management capacities and ex-port. Addressing clearly the data gaps and informal waste managment practice are important ele-ments of such confidential documentation. The establishment of an integrated system for hazardous waste management includes the es-tablishment of adequate separation at source logistics, appropriate collection and transportation of hazardous waste, construction of regional storage capacities, the construction of facilities for physical-chemical treatment, the establishment of incineraton infrastructure for hazardous waste as well as oportunities for hazardous waste landfillling. Hazardous wastes that cannot be treated in the country should be stored temporary in regional storages for collection and export of such waste to authorized plants abroad. These regional storages have an important role in the treatment and disposal chain of hazardous waste and should serve for collection, re-packing and labelling of hazardous waste intended for export or intended for treatment and disposal within the country. The capacities of cement industries and industrial thermal plants should be used preferably for incineration of certain types of hazardous waste, with the full control of emissions. The permit for waste management will define the requirements that must be met for the activities in the plant. Other hazardous waste typest hat need incineration should be exported to appropriate facili-ties abroad until – in mid term – national capacities have been built up.


The mechanisms for resolving historical pollution, and/or removal of damage to environment due to inadequate waste management should be further developed. Such sites polluted with hazardous substances should be identified all over the country; risk assessment should be per-formed in ordert o identify the priorities for rehabilitation. Responsibilities for such rehabilitation processes and measures must be defined. Hazardous waste generators generating important quantities of hazardous waste shall be obliged to establish waste management plans and to document their waste management options. The collection and treatment of packaging waste polluted with hazardous substances should be carried out in compliance with the principles of hazardous waste treatment. The possibility and conditions under which the packaging waste polluted with hazardous substances could be burnt in cement plants (e.g. waste packaging polluted with pesticides or chemical substances) should be taken into consideration.

9.5.1 Objectives for hazardous C&D waste including asbestos waste management

Objectives regarding the prevention of C&D waste generation

Following objectives on the prevention of C&D waste generation should be part of an overall na-tional waste prevention programme:

Introduction of the life-cycle aspect to force prevention of C&D waste considering all levels of the life cycle from planning, through construction and use, to final dismantling and reuse. In-volvement of planners, surveyors and construction engineers as well as the waste manage-ment operators.

In order to promote prevention of C&D waste in the future time the following measures should be considered: low-waste construction; extending the useful life of buildings; avoiding the use of hazardous substances; selective (recovery-oriented) de-construction and environmental sound C&D waste recycling.

Introduction of measures to collect and keep records of information on building materials used for the current stock of buildings and especially for new buildings to be constructed with a view to recyclability and selective de-construction. E.g. via introducing a building material in-formation system. The public sector in terms of Green Public Procurement can play the im-portant role of a frontrunner in this.

Introduction and establishment of measures to force sustainable building construction in the building sector. This might be done e.g. by introducing standards for sustainable building con-struction which give a guideline to consider general environmental aspects for the construc-tion of new buildings.

Additional measures could comprise:

o Introducing the aspect on “low-waste construction” to general education, courses of relevant studies (e.g. architecture) and to trainings for planners, surveyors and construction engineers;

o Introducing the aspect on sustainability to the minimum requirements in terms of issuing of building permits;

o Establishing the pre-condition of consideration of sustainability in the building sec-tor for possible public financial promotions.


The proposed objectives should be supported by the establishment of standards and guidelines. Working Groups on Ministry Level and Association Level might be a proper instrument to further elaborate and apply the described objectives.

Objectives related to the identification and classification of C&D waste

Before de-construct a site or dismantling a building or even undergo the refurbishment of a building a screening for hazardous substances shall be performed. As a result of this screening a plan for the removal and/or separate collection of hazardous components and contaminated fractions shall be prepared. Based on this plan relevant hazardous materials need to be removed before de-construction where feasible. Hazardous components and contaminated fractions shall be source separated on-site and classified according to their hazardous waste code.

The dismantling plan should be made mandatory in the approval procedures for a demolition or de-construction permit.

The Institute for Standardization of Serbia (ISS) can play an important role in developing relevant standards and technical reports for the recovery orientated dismantling of buildings and construc-tions.

Objectives related to the collection of C&D waste

C&D waste generally is generated at a construction or demolition site. The person/company re-sponsible for the construction/de-construction is responsible to manage the generated waste in an environmental sound manner.

This means that waste streams from C&D can be

brought to a collection point/system or another company (bring system) pre-assuming that the owner has relevant permits for collection/transportation of waste;

treated by the owner himself (incl. on-site treatment) pre-assuming that the owner has rele-vant permits for storage/treatment/disposal/recovery of waste;

or the responsibility for transportation or treatment (incl. on-site treatment) can be handed over by contracting another company which has the relevant permits.

Relevant permits need to be valid.

According to the high diversity of waste and different site conditions and the timely limitation of construction/de-construction activities an own collection system for C&D waste does not make sense and is not typically installed throughout European Countries.

If the amounts of waste generated at the construction/de-construction site are comparable to those generated from households the management/collection of the (hazardous) waste streams from C&D might be attached to the public waste collection schemes (e.g. public collection points). How-ever, up to now no comprehensive collection schemes for hazardous wastes from households have been established on the territory of Serbia.

Objectives related to the transport of C&D waste

According to Article 35 of the Law on Waste Management hazardous waste potentially contaminat-ing C&D waste (e.g. WEEE, lamps and asbestos containing waste) needs to be transported sepa-rately from the non hazardous C&D waste.

The person/company carrying out the transport of waste needs to have a valid permit for transpor-tation of waste from the competent authority. Waste carriers need to perform the transport in com-pliance with permit for transport of hazardous waste and requirements regulating special provisions on hazardous substances (ADR/RID/ADN etc.).


Some of the hazardous waste streams from C&D waste are defined as dangerous goods under ADR (the European Agreement concerning the International Carriage of Dangerous Goods by Road).For these materials a proper packaging and labelling in accordance with the ADR agree-ment is mandatory. Packaging and labelling has to be done at the place of generation. Examples are: Asbestos based insulation material, (17 06 01*), Asbestos based construction material (17 06 05*), PCB containing C&D waste (17 09 02*).

Road inspections should be carried out preferably in joint inspections between the Ministry of Envi-ronment and the Ministry of Transport to guarantee adequate effectiveness of controlling waste transports. The carriers need to enable the competent inspector to inspect the vehicle, shipment and related documentation.

Objectives related to the treatment of C&D waste

The on-site separated hazardous and non hazardous wastes need to be treated in suitable treat-ment plants with valid treatment permit from the competent authority. The operator of the waste treatment facility needs to perform waste treatment activities in compliance with the permit.

For contaminated wood the preferred treatment option is thermal treatment with energy recovery. There are capacities for co-incineration available at cement kilns for specific waste containing oil and waste oil. Capacities need to be build up for the treatment of contaminated waste wood, possi-bly in existing co-incineration plants.

Also for PCB containing waste the preferred treatment option probably is thermal treatment with suitable flue gas treatment. Due to the fact that no amount of this waste has been reported to be generated in 2014 there is no need for capacity building and until this waste stream is generated in low amount export would be the preferred option. In case of high volume low contaminated mineral waste (e.g. PCB contaminated concrete) a permanent underground storage (D12) might be the en-vironmentally preferred option, taking into account the greenhouse gas emissions connected with a thermal destruction of PCB.

For hydrocarbon- or PAH-contaminated soils the preferred treatment option is biological treatment. As biological treatment of soil is a technically easy treatment required capacities can be estab-lished in short timeframes. Yearly amounts on the generated contaminated soil may vary widely since this waste arises only at contaminated sites and the generated amount is related to single site clean-up. If biological treatment is not suitable according to the quality of the soil either chemi-cal-physical treatment as pre-treatment or co-disposal at sanitary landfills as final treatment would be appropriate options.

Special regard needs to be given to the management of asbestos containing waste. The drafted Waste Management Plan for Asbestos-containing waste gives information on a functioning system for the save collection, storage, treatment and disposal of asbestos waste and asbestos containing waste.

Relevant regulations on workers safety need to be considered (e.g. the Rulebook on preventive measures for safety and health at work that exposes to asbestos, Official Gazette of the RoS, No. 108/15 replacing No. 106/09).

To ensure proper treatment relevant information on regulative and informative aspects concerning the management of C&D waste needs to be shared with all relevant stakeholders and involved par-ties.


Objectives related to the disposal of C&D waste

Nearly all local dump sites, on which local self-government units dispose of waste in a semi-controlled manner, are registered but not permitted for disposal of waste. If disposal of mixed C&D waste at those landfills or at unregistered/unlicensed wild dumpsites takes place this needs to be addressed and banned.

Generally hazardous components/materials need to be separated on-site via source separation and the remaining mineral non-hazardous C&D waste might be disposed of at registered landfills for non-hazardous waste with valid permit. Preferable only those mixed C&D waste should be di-rected to landfills where recycling is not possible according to quality reasons.

According to the Regulation on Landfills ("Official Gazette of RS ", No. 92/2010) hazardous waste which meets parameter limit values for hazardous waste disposal shall be disposed to the landfill for hazardous waste. Specific hazardous waste like construction asbestos-containing waste and other asbestos waste meeting the conditions in accordance with the special regulation shall be dis-posed of at landfills for non-hazardous waste at clearly marked areas without being tested. This covers asbestos containing waste which does not contain other hazardous substances apart from bound asbestos.

Capacities for disposal of asbestos containing waste at clearly marked areas at non hazardous landfills are sufficient for the next years. Also hazardous waste bituminous mixtures containing coal tar can be disposed of at landfills for non-hazardous wastes since it is a non-reactive waste with a leachate characteristic comparable with non-hazardous waste.

General objectives related to asbestos waste Separate collection of hazardous waste potentially contaminating C&D waste is an important measure on construction and demolition sites in order to enable recycling of mineral residues origi-nating from such activities. Asbestos is the most important fraction of contaminated waste within C&D waste. Such hazardous components have to be identified, separated, collected and trans-ported separately to appropriate treatment and disposal facilities. Up to now there is no general management system for hazardous C&D waste established in Serbia. It should be part of the C&D management plan. The overall objective of the Serbian Waste Management Plan for Asbestos-containing Waste, (2012 11 draft) is to set up for a comprehensive system of collection, storage, treatment and dis-posal of asbestos wastes and asbestos containing wastes operated by the formal sector exclusive-ly. Asbestos-containing waste must be separately collected, packed, stored and disposed off. Asbes-tos-containing waste shall be prepared for transportation and disposal by applying packaging, surface hardening or immobilization by solidification, in order to prevent release and distribu-tion of asbestos fibres in the environment. Weakly bound asbestos waste must be packed in appropriate non-permeable certified packaging. Asbestos waste might be landfilled with non-hazardous waste without previous analysis if its origin is known, and provided that it contains no other hazardous substances. The landfill cassettes containing asbestos waste must be managed in such way that the release of asbestos fibres and dust into the environment can be prevented.. Goals regarding the prevention and reduction of asbestos-containing waste Asbestos wastes are primarily a historical problem. Therefore, there is no possibility for asbestos waste prevention. However, when demolition of asbestos contaminated building takes place, the generation of asbestos waste can be minimized by certain measures which are part of best prac-tice.


If asbestos cement and/or weakly bound asbestos are not removed before demolition or disman-tling of a building a large amount of additional asbestos containing and hazardous waste will be generated. So far, any increase in the registered amount of generated asbestos wastes is therefore a benchmark for the success of measures to install a sound collection system for asbestos wastes. Asbestos cement was used for water and waste water pipes to a large extent and is still in use. Providing inliner systems in such pipes can reduce the risk of exposure to asbestos fibres and in-creases the time of service. This will elongate the time frame for the necessary disposal of such waste. Goals regarding the collection and reuse, recycling and recovery, treatment and disposal of asbestos waste, including capacities of waste management facilities No targets for collection, re-use, recycling and recovery can be introduced for asbestos wastes since further use of asbestos is widely restricted. For most asbestos wastes (asbestos cement) di-rect landfilling or (in case of weakly bound asbestos) landfilling after solidification with cement is the preferred disposal option. Especially since asbestos and asbestos cement is not liable to produce a leachate. It may be technically and economically not feasible to set up specific recycling installa-tions for such waste streams in Serbia. During the transition period for the up-grading existing landfill sites the existing landfills for munici-pal waste may apply for a license to co-dispose asbestos wastes in specific compartments. A co-disposal on existing landfills may occur for the time being on basis of a case by case decision and a certificate which proofs that the asbestos containing wastes can be co-disposed on a landfill for non hazardous wastes. Another option may be an intermediate storage on the landfill site, if the landfill has already applied for a license to dispose off asbestos wastes. At the moment only a very limited number of companies are licensed to collect or dispose asbestos wastes. However even this limited capacity is not fully used. To avoid long transport distances a geographical distribution of adequate landfills over the whole territory of Serbia is preferable. Since gas cylinders are not allowed to be landfilled because they also contain an inflammable sol-vent which cannot drain off totally without dismantling the cylinder these wastes should be prefera-ble exported to adequate facilities existing e.g. in the European Union (e.g. Germany). These ex-ports are subject to a notification procedure in accordance with the Basel Convention. The removal of asbestos from fixed installations (industrial and non industrial) shall be done only by authorized companies and trained personnel. Permits shall be in accordance with Article 59 ff of LWM. The issuing authority of such a permit for the treatment (including removal) of asbestos waste shall scrutinize the qualification of the staff when issuing such a permit. There is a need to raise the awareness of other professionals for the issue of asbestos. E.g. roofers, plumbers, elec-tricians, stove-fitter shall be informed on the hazards related to asbestos and trained to identify as-bestos containing products. It can be assumed, that the smallest waste stream containing asbestos are movable WEEE prod-ucts containing asbestos (e.g. heat protecting shields, asbestos containing small electrical appli-ances like toaster, hair dryer, etc.) in private households. Although this waste stream is the small-est one, it may contribute widely to the exposure of the general population to asbestos fibers. For a quick removal of these wastes a household near collection system seems to be appropriate. There are synergies in the collection with the collection of other hazardous wastes from households and the collection of WEEEs.


During collection and treatment of such asbestos containing WEEEs specific precautions are nec-essary. The most important step therefore is the identification of this equipment. The necessary capacity for treatment of such devices will be rather small. For that reason the export of such de-vices to specialized recovery plants in the European Union can be envisaged as a more economi-cal solution. The direct landfilling of asbestos containing devices can also be an option (provided they do not contain other hazardous substances). However the staff of the dismantler of WEEEs needs to be trained to identify asbestos in order to exclude these devices from entering the normal recycling scheme. Specif objectives for asbestos-containing waste Identify asbestos containing wastes in specific waste streams Produce, as far as feasible, an inventory of asbestos in use Identify existing storage, treatment and disposal capacities and continuous updating Provide stakeholders with the necessary information on treatment and disposal options and

with the data on disposal capacities. Describe the adequate collection, storing, treatment and disposal infrastructure.

Depending on the type of asbestos containing waste, different requirements for their handling exist. It is the first priority to minimize the exposure of the population in general as well as of professionals to asbestos fibers. Therefore for different waste stream specific handling measures and awareness raising campains are necessary. Adequate technical equipment and installations for the save handling of asbestos as well as a trained staff are necessary. The personnel involved in the disposal of asbestos containing wastes need to be trained in both, identification and safe handling of asbestos wastes.

Gaps in the legal framework as well as in the technical approach to the asbestos management shall be identified and proposals for closing such gaps shall be made.

Prioritization of objectives for asbestos waste 1. The highest risk of fibre exposure is related to household applications of unbound asbestos

(heat shields, toaster with asbestos insulation, etc.). Public awareness raising and providing an adequate collection infrastructure for hazardous wastes from households should be the first priority. A collection system for hazardous wastes from households is foreseen in the time pe-riod 2015 to 2019. An awareness raising campaign with the goal to cover the whole waste stream/stockpile of these wastes should therefore be envisaged as soon as a collection infra-structure is available.

2. It has to be secured that in the case of fibres exposure (e.g. if the mantling of a thermal insula-tion made of asbestos is damaged) a quick removal takes place. Asbestos cement exposed to open weathering may release more and more fibers. Cement roofing and facades should be removed as soon as economically feasible especially in cases where the surface is widely de-stroyed. Based on the typically lifetime of asbestos cement roofing those older than 25 to 30 years should be the first priority od control.

3. As a further action the legal basis for a comprehensive rulebook for C&D wastes should be es-tablished in the law. Such a rulebook should cover all relevant waste streams from construc-tion and demolition of buildings and infrastructure and also hazardous waste streams like as-bestos containing wastes and PCB containing wastes from such sources.

4. At the moment the major part of asbestos wastes generated is disposed of without identifica-tion and proper handling. This may be caused by lack of awareness as well as by intent (to avoid higher disposal costs). Inspections especially of demolition works and building rehabilita-tion by the competent authorities are necessary to raise the percentage of sound rehabilita-tion and disposal activities.


9.5.2 Objectives for medical waste management

Further implementation of the initiated process for mandatory sorting of medical waste at source must continue, distinguishing between hazardous and non- hazardous waste compo-nents. All healthcare institutions must adopt the plans for waste management and designate a person responsible for waste management. Provisional solution for treatment of the infectious medical waste is disinfection and sterilisa-tion and then crushing and landfilling. Nevertheless a facility for thermal treatment of such waste (and others like pharmaceutical waste) i.e. an incinerator should be established in the long-term.

9.5.3 Objectives for hazardous waste management from households

Hazardous waste f r o m households needs separate collection which should be operated with-in the m u n i c i p a l centres for recyclable waste collection. These could also be mobile units discarding such waste in municipal or regional storage facilities. Minimum timing of such municipal collection activities is once or twice per year, with previous announcement of the population.

9.5.4 Objectives for hazardous packaging waste management

General objectives Having in mind that under Serbian LPPW three collective schemes have been established dealing with packaging waste from commercial and household waste, the first objective regarding the col-lection of hazardous packaging waste should be focused on collection schemes for packaging waste from agriculture and similar activities. During discussion s with the ministry in charge some other objectives had arisen, as follow: An implementation plan containing an investment cost estimate should define the necessary

funds that have to be injected into the market in order to make the hazardous packaging waste waste management system sustainable.

Packaging waste from commerce and household is also an important waste streams to be separately collected; such containments with residues from paints, solvents, household clean-er or care products should be separated from normal household waste collection and treat-ment system.

Metal drums that have contained lubricants may be marked as re-usable, and collected sepa-rately for re-use in a specific number of cycles. Thus, the generated waste quantities can be minimized.

Voluntary scheme or legally mandatory scheme Across the EU there are two models for hazardous packaging management schemes: the voluntary and the legally mandatory model. The voluntary model is is driven by organizations that have set up voluntary schemes for their sec-tor e.g. for pesticide producing chemical industry; pesticides trade associations have established many voluntary schemes around the world, as a component of a product stewardship programme. Such voluntary schemes can be successful where all the suppliers within a country are part of a trade association and contribute to the scheme. However, in Serbia and in other countries themar-ket is also supplied by manufacturers which are not members of trade associations and/or do not want to contribute to the hazardous packaging management scheme. In the long run such volun-tary schemes are unsustainable.Sustainable collection schemes will only be achievable in the long term where there is a secure source for funding. This can be achieved with a scheme where this is legally mandated.


Legally mandatory schemes are those that are often required under a country’s pesticides regula-tions. Generally, as part of a pesticides registration and authorization for use, there is a require-ment for users to participate in the scheme. If the country chooses the legally mandatory scheme, a sustainable funding mechanism can be established in the regulations. Where levies are imposed on suppliers of hazardous substances and its containments (e.g. pesticides), all are obliged to fi-nance the scheme. On the other hand, the threat of establishing legally mandatory schemes by the governments could be sufficient incentive for suppliers to establish voluntary schemes that operate successfully. All schemes should avoid direct charges to users for returning containers. The locations to which users may return empty containers should be convenient and avoid additional effort. In all cases, it is necessary to fulfill the waste hierarchy after collection; this means hazardous packaging waste (metal and plastic containments) has to be:

Recycled or –if this is not feasable - thermally treated (incinerated, co-incinerated or used as alternative fuel and - only if this is

not feasable – landfilled at an appropriate landfilled site.

Special provisions for POPs-packaging waste Washing or simple rinsing of POPs-packaging waste shall be prohibited in Serbia due to the lack of adequate waste water purification standards and the fact that this method does not destroy POPs. Therefore thermal treatment of POP-packaging in adequate facilities (cement kilns) or export to hazardous waste incineration facilities is necessary. The input of POP-packaging into cement kilns in Serbia could be envisaged, depending on the technology used by the cement industry. It is recommended to assess the facility’s permits in detail with regard to the possible incineration of POPs-wastes. As shredding of POP-containing packag-ing may be necessary prior to the input into the cement kiln, emissions of exhaust air resulting from the shredder process must be captured and purified (e.g. feeding them to the cement plant).


9.5.5 Determination of objectives for waste oil management

General objectives The overall objective of the SWMP for Oil Wastes is to establish an effective management system (including legal, institutional and technical aspects) for all types of oil wastes in order to reduce en-vironmental pollution caused by inadequate disposal of waste oil and other oil containing wastes. This collection and treatment system has to be operated by the formal sector exclusively. Due to its high environmental impact the system must ensure complete collection of oil wastes. Waste oils must not be discharged to soil, surface and ground waters and sewage system. Al-so, mixing of waste oils during their collection and storing with substances containing halo-gen, polychlorinated biphenyls, polychlorinated terphenyls or pentachlorophenol is prohibited, as well as mixing with substances that are not waste oils, or mixing with hazardous waste. Reception points for waste oils collection should be established, as well as the collection and treatment system. Provisions must be established for retailers who sell motor oil for vehicles for taking over waste oils from end-users who purchase motor oils from him; retailer keep record and transfer such oil to collectors for further treatment. Waste oils treatment processes for re-use (regeneration and re-refinement) are advantageous with respect to energy recovery or other appropriate treatment processes. But appropriate fa-cilities are lacking in Serbia. Therefore energy recovery from waste oil is common in Ser-bia. Appropriate treatment of waste oils and/or waste edible oils may be conducted in state-of-the-ar t treatment plants only. Fees should be introduced for producers and importers of fresh oil that becomes waste oil after use. The fee will be used for financing collection and treatment of waste oils. Waste oil activities like collection, storage and treatment of waste oils need a permit, must keep record and must re-port relevant data to the competent authorities. Goals regarding the prevention and reduction of the generation of waste oil and other oil containing wastes Establish a comprehensive data basis on lubricant consumption and waste oil generation by

individual industrial activities, to serve as a basis for future determination of quantitative goals related to the prevention of waste oil and other oil containing wastes and concerning measures necessary to achieve such goals.

Reduce soil and ground water pollution caused by losses of lubricants from machinery and equipment used in agriculture, forestry, mining, railways and caused by inappropriate disposal in the sewer system.

Goals regarding the collection of waste oil and other oil wastes Increase quantity of oil and other oil containing waste collected in Serbia by the formal sector

in order to use such waste as secondary raw material or as residue derived fuel (RDF) within the country.

Establish a collection network for all types of oil wastes derived from industry and commerce (garages, repair shops) in the area of the Republic of Serbia.

Install sufficient collection facilities for waste oil from households in the context of establishing a nation-wide system for separate collection of hazardous wastes from households.

Achieve certain collection rates (as percentage of the market input).


Goals regarding reuse, recycling and recovery, treatment and disposal of waste, including capacities of waste management facilities In order to establish an effective treatment system for all types of oil wastes arising in the Re-public of Serbia the following measures are priority: Provide sufficient capacity for the (pre-) treatment of all types of oil containing wastes (consid-

ering data on current generation in Serbia) Ensure that waste oil quantities corresponding to a certain percentage of market input ( 50%

by the end of 2019) are treated in licensed treatment plants Ensure that all licensed waste oil treatment plants apply BAT and comply with environmental

requirements as prescribed in the respective legislation, in particular regarding limit values for emissions to the air and water and concerning quality standards for waste derived fuels in Serbia.


9.5.6 Determination of objectives for waste batteries and accumulators’ management

General objectives The overall objective of the SWMP for batteries and accumulators is to establish an effective man-agement system including legal, institutional and technical aspects for such waste in order to re-duce environmental pollution caused by inadequate disposal of waste batteries and accumula-tors.This is especially important for batteries containing harmfull substances like mercury and cad-mium. The trade with batteries and accumulators containing mercury is prohibited in Serbia. Landfilling and burning of used batteries and accumulators is prohibited in Serbia, as well. A system of col-lection points (public buildings, retailers, supermarkets, other relevant points) should be estab-lished, and the consumers should be encouraged to deliver such waste batteries and accu-mulators to these collection points. Labelling of batteries and accumulators should include in-structions and warnings for separate collection, contents of heavy metals and opportunities of recycling. Collection rates of at least 25% on a medium term and rates of at least 45% on a long term should be aspired. With respect to economic instruments, the payment of fees must be introduced for producers and importers of batteries and accumulators that become waste upon their use. This fee will be used for collection and treatment of such waste. A person that conducts collection, storing and treatment of used batteries and accumulators must have a permit, must also maintain and keep records on used batteries and accumulators and the collected, stored and treated quantities, and must report relevant data to the Agency. Goals regarding the prevention and reduction of waste generation Producers of batteries and accumulators should limit the amount of hazardous substances in bat-teries and accumulators that are put on the Serbian market. Mercury containing portable consumer batteries should be banned from the market. Goals regarding the collection of waste batteries and accumulators Establish a collection network for all types of batteries and accumulators including necessary

activities for legal, institutional, financial and technical set up. Collect all types of batteries and accumulators in the area of the Republic of Serbia and Achieve – in medium term – the collection rates as defined in the legal framework.

Goals regarding reuse, treatment, recycling and recovery and disposal of waste, including capacities of waste management facilities To establish a management system for all types of batteries and accumulators to provide options to properly treat them and achieve – on a medium term – recycling efficiency values as defined in the legal framework.

9.5.7 Determination of objectives for WEEE management

General objectives The overall objective of the SWMP for WEEE is to establish an effective management system (in-cluding legal, institutional and technical aspects) for such waste in order to reduce environmental pollution caused by inadequate disposal of WEEE. Due to its increasing amount and its increasing economic value such wastes are important sources for secondary raw materials. The system for separate collection of electrical and electronic products should be established in a manner that the usable parts can be recycled and valuable secondary raw materials can be extracted.


The waste components of electronic and electrical products containing PCB must be separated and their appropriate disposal must be ensured. It is necessary that a separate recovery of re-frigerants should be established. Waste fluorescent tubes containing mercury Waste fluorescent tubes containing mercury must be collected separately and treated before disposal. The Law prescribes the procedure for managing waste fluorescent tubes containing mercury. The person that conducts collection, storage and treatment of fluorescent tubes must have a permit, must also keep records on fluorescent tubes and the collected, stored and treat-ed quantities and must report such data to the competent authority. At present there is no suitable treatment facility in Serbia and export for appropriate treatment is necessary. In a medium term a national solution is desirable. Goals regarding the prevention and reduction of waste generation Producers of electrical and electronical devices should limit the amount of hazardous substances in such products that are put on the Serbian market. This can so farreduce the overall hazardous-ness of WEEE being generated in future. Goals regarding the collection of waste (collection systems) A collection network for all types of WEEE shall be established in the area of the Republic of

Serbia including legal, institutional, financial and technical issues in order to achieve collection targets set by the legal framework. This implies increase of the amount of WEEE collected separately from households by the formal sector in terms of specific quantities (kg/inh and year) by the end of 2019.

Continuous increase of the amount of certain types of WEEE of high environmental relevance collected from households and commerce in terms of specific quantities (kg/inh and year) by the end of2019. Such relevant devices are cooling and freezing equipment, screens and lamps.

Responsibility to achieve collection targets is not defined in the Serbian law. This responsibility for financing and operating related collective schemes should be assigned to the producers. Collection targets should be adapted to EU Directive.

Municipal and private collection sites and storage capacities should be placed in the near fu-ture; therefore a strong involvement of the municipalities and waste management operators is desirable. Such adequate collection and storage infrastructure on a local level is crucial to reach the collection targets.

Reporting of collected quantities of WEEE should distinguish between WEEE from households and WEEE from the business sector. Additionally, cost structure and financing are different for both parts of WEEE management.

Goals regarding reuse, recycling and recovery, treatment and disposal of waste, including capacities of waste management facilities Establishment of an efficient management system for all types of WEEE collected in the area

of the Republic of Serbia including legal, financial and technical framework in order to achieve that all collected WEEE and components are treated in an environmental sound way, i.e. dis-mantled and de-polluted properly.

Recovery/recycling targets are achieved for all collected WEEE types. Regulation of financing system for special waste streams treatment.


Prioritization of objectives Most important for establishing an efficient WEEE management system, is to clarify the legal

framework, to decide which entity shall run the WEEE management system and to establish a collection network throughout Serbia.

Increasing collection rates and increased amounts of WEEE being treated in an environmental sound way have to be achieved continuously.

9.5.8 Determination of objectives for ELV management

Objectives regarding prevention of ELVs To implement extended producer responsibility with the aim of encouraging waste prevention by

fully transposing the ELV Directive. A proposal for an amended legislation in Serbia was elabo-rated within this Twinning Project. The amended legislation would define the legal requirements which have to be respected by the vehicle manufacturers and the operators of treatment facili-ties. Responsibility: MAEP;

Vehicle manufacturers, in liaison with material and equipment manufacturers, limit the use of hazardous substances in vehicles and reduce them as far as possible from the conception of the vehicle onwards, so as in particular to prevent their release into the environment, make re-cycling easier, and avoid the need to dispose of hazardous waste. Responsibility: vehicles manufacturers;

Design and production of new vehicles take into full account and facilitate the dis-mantling, reuse and recovery, in particular the recycling, of end-of-life vehicles, their components and materi-als. Responsibility: vehicles manufacturers;

Vehicle manufacturers, in liaison with material and equipment manufacturers, integrate an in-creasing quantity of recycled material in vehicles and other products, in or-der to develop the markets for recycled materials. Responsibility: vehicles manufacturers;

The presence of hazardous substances shall be clearly labelled. Responsibility: vehicles manu-facturers;

o Ensure that automotive manufacturers provide dismantling information on compo-nents and material for treatment operators to promote the environmentally sound treatment of ELV’s, safely and economically. The IDIS system (International Dis-mantling Information System) may be used for this purpose. Responsibility: auto-motive manufacturers ;

The entity that treats end-of-life vehicles shall provide for separation of hazardous materials and components from end-of-life vehicles in order to enable further treatment before the disposal. Responsibility: operators of treatment facilities;

Materials and components of vehicles put on the market do not contain lead, mercury, cadmium or hexavalent chromium. Responsibility: vehicles manufacturers;

To organise a sufficient supervision of the legal requirements by the competent authorities in or-der to implement the objectives of the ELV Directive and to guarantee a level playing-field for the economic operators. Responsibility: MAEP, local authorities.

Improve waste management planning, quality of the data and projections and update the nation-al WMP/develop the regional WMPs – Responsibility: MAEP/SEPA/APV/LSG

Develop the Waste Prevention Programme (including the management of ELV’s) Responsibility: MAEP/SEPA/APV/LSG


Objectives regarding the collection of ELVs Establish an integrated system for collection, storage, treatment, recycling/recovery/reuse (spare

parts) of ELV. In order to increase the collection of end-of-life vehicles, an adequate number of authorized collection facilities shall be made available for the citizens and covering al the coun-try’s territory. Responsibilities: The Ministry (legal basis and supervision), local authorities (su-pervision) and private stakeholders (implementation);

Enforce Extended Producer Responsibility (EPR) schemes in order that the manufactur-ers/importers of the vehicles on the national market take the full responsibilities for the collec-tion, storage, treatment, and recycling/recovery of ELV. Responsibilities: The Ministry (legal basis and supervision), local authorities (supervision) and private stakeholders (implementa-tion);

Introduction of financial incentives at national level to surrender ELV only to authorized collection or dismantling facilities. Such a measure would reduce the number of illegally acting collection and treatment facilities and would minimize the problem of illegal disposal of ELVs (abandoned vehicles) in public places. Responsibility: The Ministry);

Improve the actual situation related with disposal of shredder residues through implementing of post shredder technologies and establishing a landfill tax. Responsibility: The Serbian central authorities;

Initiate awareness raising campaigns on collection and treatment of ELV for different target groups. Responsibility: The Ministry, the Environmental Agency, local authorities, ONGs and private stakeholders.

Objectives regarding treatment, the reuse, recycling, recovery and disposal of ELV, including ca-pacities of waste management Take the necessary measures to ensure that all end-of life vehicles are transferred to authorized

treatment facilities. Responsibilities: The Ministry (legal basis and supervision), local authorities (supervision) and private stakeholders (implementation);

Take the necessary measures to ensure that treatment, recycling, recovery and reuse of ELVs is carried out according to the best available techniques. Responsibilities: The Ministry (legal ba-sis and supervision), local authorities (supervision) and private stakeholders (implementation);

Take the necessary measures to ensure that the targets for re-use, recycling and recovery will be achieved. Responsibilities: The Ministry (legal basis and supervision), local authorities (su-pervision) and private stakeholders (implementation);

Improve the reporting system in order to have reliable data on the management of ELV. Re-sponsibilities: Environmental Agency, private stakeholders

9.5.9 Determination of objectives for PCB and other POP waste management

(Stockholm Convention)

General objectives of POPs waste management The National Plan for the Implementation of Stockholm Convention (NIP) has been prepared. An action plan for PCB waste, waste pesticides and unintentionally released chemicals (diox-ins and furans) has been integrated.


Provisions of this Plan now have to be implemented: Owners of POPs waste report the type and quantity of this waste to the ministry in

charge. Appropriate storage facilities for t h e collection of PCB waste and f o r equipment contam-

inated with PCB must be established. Smaller temporary storage facilities for occasional collection of waste pesticides in r u r a l regions have tob e set up, until their collection in regional storages for final treatment is launched.

Sites contaminated with POPs shall be identified and the monitoring of POPs in the envi-ronment shall be introduced. A reliable nation wide inventory of POPs waste has to be pre-pared.

Public awareness raising and education about POPs waste and its treatment in general are important goals. The competent authority keeps record on the devices in use containing PCB. The person that conducts collection, storage and treatment of PCB waste need a permit, must also keep record and have to report such data to the competent authority.

IPPC is an instrument ensuring the environmentally sound management of POPs waste. It is nec-essary to promote the use of Best Available technology (BAT) and of environmentally sound prac-tises as well asencourage the implementation of emission limits for the IPPC installations. The im-plementation of the Directive 2008/1/EC on IPPC can contribute largely to the reduction of uninten-tionally produced POPs. Goals of the Communication Strategy for Stockholm Convention General goal of the Communication Strategy is to improve the level of awareness and acquisition of knowledge amongst stakeholders and general public about the risks that POPs chemicals pose to human health and environment. Specific objectives are the following:

Improvement of knowledge and integration of competent institutions, professional and in-terested public into the implementation process of the StockholmConvention;

Improvement of knowledge and awareness amongst professional users (managers and staff whose job implies higher risk of chemicals, occupational associations, unions, etc.) about risks of POPs chemicals and guidelines for appropriate protection measures;

Raising awareness amongst general population in order to facilitate appropriate handling and separate collection activities for POP wastes

Pursuant to these goals and objectives, the following activities are planned (excerpt):

Educational activities (workshops, seminars, lectures) have been focused on the Stock-holm Convention and on POPs chemicals;

An increased number of institutions, organisations and individuals have been involved in the implementation of NIP and specific activities;

Educational and information materials and manuals for professional users has been devel-oped;

Cooperation with occupational and other associations has been established; Campaigns and other activities have been focused on the promotion ofNIP and the Con-

vention implemented.


Goals in the context of retro-filling of equipment that originally contained PCB Based on the experiences gained elsewhere, retro-filling generally cannot be recommended.

In the past in many cases the limit value for PCBs was exceeded by retro-filled transformers within a few months. In this context, the immediate objective must be that in the adopted Min-isterial Order on PCBs a stipulation should be implemented, that analyses of the fluids shall be required, when the equipment is taken out of operation. Depending on the results of these analyses the appropriate treatment is to be foreseen in compliance with the Ministerial Order on PCBs.

A second objective must be a stipulation that simple washing of PCBs-containing electrical equipment with a solvent and subsequent treatment by means of shredding is not permitted because it leads to dioxin formation during shredding and contamination of the shredded waste with PCB. Before recovery of the metal parts from PCBs-bearing electrical equipment, a complete decontamination is necessary.

As for the pre-treatment process, all these operations are to be carried out in a suitable au-thorised plant with a secure black zone. Special precautions are necessary, particularly re-garding the carrying out PCB-decontamination (airlock, treatment of exhausted air etc.).

Goals in the context of storage facilities for POPs waste Another priority objective for POPs waste management is the transfer of POP waste from inade-quate intermediate storage facilities to suitable intermediate storage facilities; in this context, in-spections and if necessary, repackaging of obsolete pesticides and other POPs should take place. Such temporary storage facilities should be adjusted to the state-of-the-art standards at the earliest possible stage. Otherwise, the establishment of new storage facilities complying with the state-of-the-art standards should be considered. Suitable solvent-resistant containments shall be used dur-ing intermediate storage and transport. Goals in the context of incineration of POP waste Cement kilns provide temperature profiles and gas residence times which are comparable to

specialized waste incinerators. Cement kilns do exist in Serbia; high temperature incinerators do not. Therefore cement kilns in Serbia could burn low levels of PCBs and POPs in the firing systems, if the facility’s permits allow the input of such wastes up to a specific limit and if it complies with the emission limits according to the EU WID. One of the priority goals of POP waste policy in Serbia could be to incinerate suitable wastes with higher PCB/POPs-contents than specified in Annex IV of the POPs Regulation because high temperatures in cement kilns normally destroy POPs and the formation rate of dioxins in cement kilns is extremely low.

Refuse (waste) derived fuels (RDF) normally may contain up to 50 ppm of PCBs. In case of waste exceeding 50 ppm of PCBs the incineration has to be qualified as D10 operation: incin-eration on land. Another goal should be to use waste oils exceeding the low POPs-content lim-it of 50 ppm (mg/kg) of PCBs in the firing systems of cement kilns.Such input limits for wastes shall be laid down in the specific cement facility’s permit; the compliance with emission limits in accordance with the EU WID, have to be checked additionally. It is recommended to assess the present facility’s permits in detail with regard to the possible incineration of POPs-wastes.

In case of production of RDF for the cement industry, binding standards should lay down for the limit values for such fuels and the tolerated emissions. Special attention has to be given to the limitation of mercury in RDF due to the former use of Hg-additives in lubricants and cutting oil emulsions.

The incineration of even low POPs-wastes in coal power stations in Serbia is no option at the moment, since these facilities do not comply with the required standards according to the EU WID.


Goals in the context of recycling activities concerning POP containing waste If in case of small capacitors (for example, start-up and compensation capacitors in washing

machines, fluorescent lamps, etc.) due to the production date and on the basis of the labelling the presence of PCBs cannot be excluded, these are to be classified as potentially PCB-containing capacitors, which shall be subject to a thermal treatment in a suitable hazardous waste incinerator or appropriate intermediate storage for export. Due to the wide distribution of PCBs-containing small capacitors the shredder light fraction from the treatment of electronic scrap may contain PCBs to a relevant extent, especially if the pre-treatment (sorting, partly dismantling) of WEEE is not adequate.

One of the objectives in the context of WEEE management is therefore that shredder fractions (fluff) resulting from dismantling and shredding processes of WEEE should be subject to ther-mal treatment (incineration). For this purpose the establishment and operation of at least one thermal treatment facility in Serbia is recommended in a medium term. This facility will be used for fluff from ELV shredding processes as well.

An inspection and adjustment of car dismantler and shredder facility’s permits to the new leg-islation is required especially with regard to the practical performance of separation of hazard-ous components and compliance with the technical minimum requirements for treatment of ELVs and WEEE as well as the environmentally sound management of the shredder fractions (fluff). Adequate dismantling prior to the shredding process can reduce the amount of fluff and increase the recycling quota.

As up to now even illegal dumping of shredder fractions took place. Landfilling to authorized landfills could be an intermediate solution This decision shall be based on analyses of the shredder fraction.

Objectives concerning contaminated sites Contaminated soils have to be identified and remediation has to take place in an environmen-

tally sound manner. Locations where chlorinated organic pesticides were produced in the past, areas characterized by the use of PCBs-containing equipment and industrial processes gen-erating PCDD/PCDF and PAH releases, chlor-alkali facilities, facilities having used vinyl chlo-ride monomers and chlorinated phenols (wood protection, leather tanning) stand the risk of contamination with POPs and require comprehensive investigations; the same applies to loca-tions where pesticides POPs were handled or stored or disposed in the past (local dump sites).

The Serbian legislation on Cleaning-up of Contaminated Soil needs further improvement with regard to responsibilities of authorities for clean-up programmes and the financing of the measures.

Objectives concerning POPs in waste oils Like mentioned above, a by-law on motor oil products should be considered in order to prevent ille-gal mixing of PCBs (and heavy metal compounds) into new oil products. Provisions must ban the placing on the market of motor oils containing the following additives: halogens, cadmium and cadmium compounds, mercury and mercury compounds,arsenic and arsenic compounds.


10 MEASURES AND GUIDELINES INCLUDING MANNER AND DEADLINES FOR IMPLEMENTATION OF THE NATIONAL PLAN

10.1 Measures

10.1.1 Measures concerning different fields of concern

10.1.1.1 Regulatory instruments

Measure Priority Sub-Measure

Main Responsibility

In co-operation with

Until when

1

Waste Framework Directive

H

A limited number of gaps and incomplete transposition have to be transposed, the best in connexion with the development of the renewed Waste Management Strategy and the elaboration of the Integrated haz-ardous waste Man-agement Plan (IHWMP)

Ministry of En-vironment

Province of Vojvodina, other state authorities

2020


2

Other hazardous waste related direc-tives and Regulation (EC) No 1013/2006 on shipments of waste

H

Few adaptions are to be accomplished in the Serbian legal framework preferably in mid tern for full transposition of Indus-trial Emissions Di-rective (2010/75/EU), former Waste Incin-eration Directive 2000/76/ЕC, Ship-ment of waste - Regu-lation (EC) No 1013/2006 and Regu-lation (EC) No. 1418/2007, Directive 2011/65/EU, 2002/96/EС on waste electric and electron-ic equipment and Di-rective 2012/19/ЕU No further adaptions are necessary for transpoasition of Council Directive 99/31/ЕC on landfills, Council Directive 2000/53/EC on end-of-life vehicles


Province of Vojvodina, Stakehold-ers (e.g. Producers)

2020

3 POPs Waste man-agement related regulations

H

Some remaining pro-vision in the context of the transposition of the Stockholm Convention or UNECE Protocol on POPs, of the Directive on the Disposal of PCBs and PCTs 96/59/ЕС and of the Regulation (EC) No 850/2004 on persis-tent organic pollutants have to be trans-posed by amend-ments of the Law on Waste Management and the Rulebook on management of the PCB containing equipment and waste.


Province of Vojvodina

2020


4 Public participation Directives

H

Transpose all prescip-tions concerning Stra-tegic Environmental Assessment in waste management plan-ning and programs Introduce Environ-mental Impact As-sessment in hazard-ous waste manage-ment planning Transpose regula-tions for public partic-ipation within Waste Framework Directive, Waste Incineration Di-rective and Industrial Emissions Directive (2010/75/EU)



2020

Legend concerning responsibiloities CoC (Chamber of Commerce) EI (Ministry of Environment and Spatial Planning, Environmental Inspectorate) P/I (producers and importers) SEPA (Serbian Environmental Protection Agency) Mun. (Representatives of municipalities) Reg. (Representatives of regions) Voj (Vojvodina) Legend concerning priority M medium = medium term activity H (high) = short term activity Ad 1: Waste Framework Directive Most of the provisions from the Council Directive 2008/98/ЕC on waste are already transposed in national legislation. Transposition of provisions related to definitions (dealer, broker, re-use, preparing for re-use), by-products, end-of-waste status, -recovery, recycling, deadline, ban on the mixing of hazardous waste, hazardous waste produced by households is not performed yet. A limited number of addi-tional gaps and instances of incomplete transposition were detected, along with a few cases of in-correct transposition. Activities in the context of the transposition of the Waste Framework directive are as follows: Mid-term (2017-2020) Full transposition will be achieved in 2018, as some parts of Directive will be transposed by

secondary legislation (regarding recycling targets), as well as by amendments of Rulebook on Categories, Testing and Classification of Waste (“Official Gazette of RS, No 56/10”).

The exact mechanism for full transposition will be determined as part of the revision of the Na-tional Waste Management Strategy and the preparation of the Integrated Hazardous Waste Management Plan. Both these documents are in the process of being prepared.


Ad 2: Other hazardous waste related directives Directive 2000/76/ЕC on incineration is fully transposed in the Law on waste management (“Official Gazette of the Republic of Serbia”, No. 36/09 and 88/10) and Decree on waste types for thermal treatment. Meanwhile this Directive has been repealed with the Directive 2010/75/EU оf 24 November 2010 on industrial emissions (integrated prevention and pollution control of the environment). With regard to the provisions related to the waste incineration, it is necessary to revise and

adapt the Law on Waste Management . Most of the provisions of the Council Directive 99/31/ЕC on landfills is transposed in the Law on Waste Management (“Official Gazette of the Republic of Serbia”, No. 36/09 and 88/10), Decree on disposal of waste in landfills (“Official Gazette of the Republic of Serbia”, No. 92/10) and Rule-book on categories, testing and classification of waste (“Official Gazette of the Republic of Serbia”, No. 56/10). No further transposition of EU regulations in the context of hazardous waste management is

necessary. In accordance with the Council Directive 2008/98/ЕC on waste and Council Directive 99/31/ЕC on landfills, the Rulebook on Medical Waste Management (“Official Gazette of the Republic of Serbia”, No. 78/10) has been adopted. No further transposition of EU regulations in the context of hazardous waste management is necessary. Council Directive 2006/66/EC supersedes and supplements the 91/157/EEC Directive on batteries and accumulators containing hazardous substances is transposed in Law on Waste Management (“Official Gazette of the Republic of Serbia”, No. 36/09 and 88/10) . Activities in the context of the transposition of the Directive on batteries and accumulators are as follows: Mid-term (2017-2020) The Rulebook on the procedure for management of waste batteries and accumulators

(“Official Gazette of the Republic of Serbia”, No. 86/2010) has partially been transposing the Directive only; this gap should be closed.

Directive 2013/56/ЕU on batteries and accumulators and on waste on batteries and ac-cumulators has not been transposed in the national legislation yet. This should be foreseen as well.

Council Directive 2000/53/EC on end-of-life vehicles is fully transposed in the national legis-lation through the provisions in the Law on Waste Management and the Rulebook on the proce-dure for end of life vehicle management (“Official Gazette of the Republic of Serbia”, No. 98/10). No further transposition of EU regulations in the context of hazardous waste management is

necessary. Directive 2011/65/EU, 2002/96/EС on waste electric and electronic equipment and Directive 2012/19/ЕU are partially transposed in the national legislation in Rulebook on the List of electrical and electronic products, measures of prohibition and restrictions on the use of electrical and elec-tronic equipment containing hazardous substances, manner and procedure for management of waste of electrical and electronic product (“Official Gazette of the Republic of Serbia”, No. 99/10). In addition, implementation of Directive 2011/65/EU already started in terms of identifying the method for implementation of provisions related to restriction of placing on the market electrical and electronic equipment containing lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers. In 2011 requirements from the Articles 5, 6, 7.2, 10 and 11.1 of the Directive were implemented. Supervising authorities were named.


Activities in the context of the transposition of the Directive on WEEE are as follows: Mid-term (2017-2020) Adaption of Rulebook is envisaged for the end of 2019, as it is demanded in the Article 5 of

the Directive. Waste Shipment Regulation - Regulation (EC) No 1013/2006 and Regulation (EC) No. 1418/2007 Regulation 1013/2006 on transboundary movement of waste is directly applicable in the Mem-ber States. The Serbian national system of supervision and control of shipment of waste is harmonised with the system of the European Union..The requirements of the Basel Convention have fully been implemented in Serbia. Serbia also fullfils the obligation of reporting in line with the Basel Convention. Reports are submit-ted annually by the ministry in charge for environmental protection as the focal point for the Basel Convention.

In the Republic of Serbia, transboundary waste shipments are regulated by the Law on Waste Management (Official Gazette of RS, No. 36/09, as amended). More specifically, this Law regulates terms and mode of transboundary waste shipments, import, export and transit of waste and prohibition of transboundary waste shipments. Related decree and Rulebooks are transposing fur-ther prescriptions of transboundary shipment in detail. Activities in the context of the Regulation on transboundary movement of waste are as follows: Mid-term (2017-2020) The additional analyses of legal framework will be performed in order to revise national legisla-

tion until 2017. Full alignment will be achieved in 2018, by revision of by-laws regarding trans-boundary movement of waste.

Ad 3: POPs Waste management related regulations Regulation (EC) 850/2004 of the European Parliament and of the Council of 29 April 2004 on per-sistent organic pollutants (POPs) and amending Directive 79/117/EEC ensure implementation of international obligations in chemicals and waste management sectors. It regulates production, plac-ing on the market, use and elimination of substances which are restricted or limited according to the Stockholm Convention or UNECE Protocol on POPs. This Regulation is transposed in the Law on Waste Management and Rulebook on the list of POPs substances, the manner and procedure for the management of POPs waste and limit values for concentrations of POPs substances related to the disposal of wastes containing or contaminated with POPs substances (“Official Gazette of the Republic of Serbia”, No. 65/11). Council Directive 96/59/EC on PCB and PCT is transposed in the Law on Waste Management (“Official Gazette of the Republic of Serbia”, No. 36/09, 88/10). This Directive is partially transposed in the Rulebook on treatment of devices and waste containing PCB (“Official Gazette of the Republic of Serbia”, No. 37/11). This Regulation contains conditions for implementation of the pro-visions (Article 4 of the Directive), which are related to the establishing and updating inventory of equipment with PCBs and require from the owner of the equipment to define competent body.


Activities in the context of the Directive on the Disposal of PCBs and PCTs 96/59/ЕС are as fol-lows: Short Term (2015-2016) Some remaining provision will be transposed by amendments of the Law on Waste Manage-

ment (which is scheduled for 2016). Mid-term (2017-2020) Remaining provision shall be transposed by amendments of the Rulebook on management of

the PCB containing equipment and waste(which is scheduled for 2018). Activities in the context of the regulation (EC) No 850/2004 on POP waste are as follows: Short Term (2015-2016) (EU) Regulation No 1342/2014 amending EC Regulation on POPs No 850/2004 will be taken

over into the Serbian national legislation until the end of 2015. Mid-term (2017-2020) Republic of Serbia will continue the process of harmonization of national legislation. In line

with further amending of the EC Regulation on POPs No 850/2004 in above mentioned period. Ad 4: Regulations on public participation Provisions regarding the public participation are integrated in the following EU directives:

Strategic Environmental Assessment Directive (Directive 2001/42/EC) Environmental Impact Assessment Directive (Directive 85/337/EEC), Waste Framework Directive (Directive 2008/98/EC) Waste Incineration Directive (2000/76/EC) Industrial Emissions Directive (2010/75/EC)

The common principle is to ensure that plans, programmes and projects likely to have significant effects on the environment are subject to an environmental assessment, prior to their approval or authorisation. Consultation with the public is a key feature of environmental assessment proce-dures. Strategic Environmental Assessment This environmental assessment procedure can be summarized as following: An environmental report has to be prepared in which the likely significant effects on the envi-

ronment and reasonable alternatives are identified, described and evaluated. The draft plan or programme and the environmental report must be made available to authori-

ties and the public. In this way they can express their opinion on the draft plan or programme and the accompanying environmental report. The opinions of the authorities, the public and the affected MS have to be taken into account during the preparation of the plan or pro-gramme and before its adoption.

If the implementation of a plan or programme being prepared is likely to have significant ef-fects on the environment in another Member State (MS), or if a MS likely to be significantly af-fected so requests, the draft plan or programme and the accompanying environmental report must also be forwarded to the affected MS.

.The authorities, the public and any Member State consulted have to be informed about the decision on the adoption of the plan or programme.

The MS have to monitor the significant environmental effects after implementation of plans and programmes in order to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action.


Environmental Impact Assessment The EIA Directive, requires an assessment to be carried out by the competent national authority for certain projects which have a physical effect on the environment. The EIA must identify the direct and indirect effects of a project including the interaction between various effects. In case of projects for waste disposal installations for the incineration, chemical treatment or landfill of hazardous waste EIA will be obligatory: The developer must provide information on the environmental impact (EIA report) to the com-

petent authority. The first and most important information for interested parties is the public announcement of the project by the authority.

In addition, the project documents must be made available for personal inspection by inter-ested parties. In this way, the public is given an opportunity to express its opinion on the grant-ing of an approval. Opinions may be submitted and these must be taken into consideration by the competent authority when it takes the EIA decision.

The public must be informed of the decision afterwards and can challenge the decision before the courts.

Waste Framework Directive According to Article 31 of the Directive on waste (2008/98/EC) Member States are obliged to en-sure that relevant stakeholders and authorities and the general public have the opportunity to par-ticipate in the elaboration of the waste management plans and waste prevention programmes, and have access to them once elaborated. They shall place the plans and programmes on a publicly available website. Waste Incineration Directive According to Article 12 (1) of the Directive on the incineration of waste (2000/76/EC) applications for new permits for incineration and co-incineration plants shall be made available at one or more locations accessible to the public for an appropriate period to enable comments before the compe-tent authority takes a decision. That decisionshall also be made available to the public. Article 12(1) WID is implemented into Serbian law in Article 23 of the GO on thermal waste treat-ment: Industrial Emissions Directive (2010/75/EU) Article 24 of the IED is very similar but more detailed than Article 15 of the IPPC Directive (2008 /1/EC). According to Article 24 of the IED, the public concerned should be given early and effective opportunities to participate in the following procedures: the granting of a permit for new installations; the granting of a permit for any substantial change; the granting or updating of a permit for an installation where the application of Article 15(4) is

proposed; the updating of a permit or permit conditions for an installation in accordance with Article

21(5)(a). The detailed arrangements are listed in Annex IV to the Directive. The public concerned is entitled to express comments and opinions to the competent authority before a decision is taken. The re-sults of the consultations held pursuant to this Annex must be taken into due account in the taking of a decision. When a decision on granting, reconsideration or updating of a permit has been taken, the competent authority shall make it available to the public. The competent authority shall also make available to the public: relevant information on the measures taken by the operator upon definitive cessation of activi-

ties in accordance with Article 22; the results of emission monitoring as required under the permit conditions and held by the

competent authority.


10.1.1.2 Operative instruments


Main Responsibility


Until when

1 Improve general lia-bilities and obliga-tions of waste own-ers

H

Transpose fully all liabili-ties and obligations of waste owners through re-peated waste control and inspection


Inspectorates, 2020

2

Improve coopera-tion and information exchange

H

Cooparation between in-dustry and ministry Cooperation between ministries Cooperation within the ministry


Other Minis-tries

2020

3 Strengthen adminis-trative capacities and procedures

H

Strengthen administrative capacities, especially the institutions and organisa-tions in charge of plan-ning, permitting, control-ling and monitoring Adopt regional waste management plans Establish local and re-gional institutions in charge of waste man-agement and capacity building


АP, LS, SЕPА, SSC

2020


4

Operational pro-grams Permitting proce-dure Inspection proce-dure Document of movement Financing of the waste management activities for the end-of-life products and responsibilities

H

Create an operative pro-gram for hazardous waste management Introduce an integrated permitting procedure for all aspects of the facility Updating the rulebook with template permissions and minimum require-ments for the permitting procedure Decide on further institu-tional measures for a bet-ter quality of permits Introduce joint inspections of different inspectorats, and of permitting staff and inspectors Coordinated joint transport inspections by police and inspectors. Introduce the documents of movement as important tools for the waste stream control Decide on the financing of end-of-life products waste management Decide on responsibilities for collection targets and performance of collection systems


Industry and waste man-agement op-erators, Municipalities and Province of Vojvodina

2020


5

Institutional frame-work for waste management Decentralisation and division of re-sponsibilities Administrative re-sources

H

Decentralization, structur-al differenciation, cooper-ation of institutions and departments must be strengthened Capacities and compe-tences must increase Private sector participa-tion must increase Decentralisation on a re-gional level as far as nec-essary, especially with municipal collection and storage facilities Centralisation of decisions and programs as far as necessary especially for hazardous waste Organization of additional external funds for new work load Re-groupment of adminis-trative ressources for permanent additional tasks

Ministry of En-vironment, Province of Vojvodina

Province of Vojvodina, lo-cal authorities EU institu-tions

2020

6

Planning and man-agement methods Indicators for the Strategy implemen-tation

H

Develop strategic plan-ning instruments Coordinate data collec-tion, planning and moni-toring activities on nation-al and regional level Develop spacial planning with regard to waste management interests Indicators for hazardous waste management pur-poses are developped and are monitored regu-larly; they are internation-ally exchanged for har-monization and develop-ment.


Province of Vojvodina, Statistical Of-fice, Environ-mental Agen-cy

2020


7

Establishment of fa-cilities and man-agement systems for hazardous waste in Serbia

H

Establish separate collection and treatment systems of hazardous household waste Build central / regional storage facilities for haz-ardous waste in 5 regionsof Serbia Ensure capacities for a strategic plant for physi-cal- chemical treatment of waste Ensure capacities for incineration / energetic re-use of organic industrial and medical waste Analysis of possibility touse existing facilities for treatment of a wider range of hazardouswaste types Rehabilitation /re-enforcement of existingstorage facilities of haz-ardous waste Development of designs for rehabiliattion and recultivation of dumpsites Close, or re-enforce exist-ing dumpsites in conform-ity with priorities and legal requirements Establish monitoring sys-tems for the recultivationof high risk locations Establish further capacities for hazardous waste landfilling

Private sector, national indus-try, national and interna-tional opera-tors,

Ministry of Environment , Province of Vojvodina, Statistical Of-fice, Environ-mental Agen-cy, Coc, col-lective schemes

2020


8

Creation of a system for special waste streams manage-ment (details see below)

H

Build regional storage fa-cilities for all types of such hazardous waste streams (see below) Build waste oil treatment plants Develop further and en-large sound management of asbestos waste Organize collection and treatment of hazardous packaging waste Build sorting units (and treatment plants) for used batteries and accumula-tors Build dismantling facilities and other treatment plantsfor WEEE Build dismantling facilities, shredders and other treatment plants for end- of-life vehicles Planning, structuring and organizing of the collec-tion and treatment of PCB waste and other POPs waste Structured replacement ofequipment with PCB/PCToils, decontamination ofplants and equipments,destruction of all hazard-ous waste materials withPCB/PCT, export if nec-essary Develop and introduce economic instruments for financing the system and for creating stimulating in-struments that will en-courage re- use and re-cycling of waste material

Collective schemes

Private sec-tor, national industry, na-tional and in-ternational operators, Ministry of Environment , Province of Vojvodina, Statistical Of-fice, Environ-mental Agen-cy, Coc,

2020

9

Promotion of re-use of waste as an alter-native source of fuel at cement factories, forges, thermal power stations and heating plants in conformity with regulations

H

Upgrade technical stand-ards for the use of waste as fuel Develop existing produc-tion facilities and technol-ogy (BAT application) for the usage of a wider range of hazardous waste types as an alternative fuel


Province of Vojvodina, Environmen-tal Agency, Industry

2020


Ad 1: Liabilities and obligations of parties participating in waste management Law on Waste Management has established liabilities and obligations for all parties participating in waste management: waste generators, i.e. waste owners, waste collection and ransport firms, operators of facilities for storage, treatment and landfilling activities. These obligations must fully be transposed. Waste generator generating more than 200 kg of hazardous waste annually shall be obliged to establish a waste management plan, to acquire a report on inspection of waste, t o apply the hierarchy principle when deciding about waste management options and to take measures fore-seen in regulations when collecting, storaging or handing over such waste.The polluter pays prin-ciple prescribes him to bear the costs of waste management including the costs of handing over the waste to the collector or to the facility for treatment or disposal. The ownership of generated waste ceases when the new owner (transport firm or treatment/disposal facility) has taken over the waste, proved by the reception of the Document on movement of waste. Waste collection and transport firms shall be obliged to carry out the transportation of waste in conformity with the obtained permit and with the requirements regulated by specific transport regulations (ADR). Operators o f the storage, treatment and disposal faci l i t ies shall be obliged to perform their activities in conformity with the permit, and to keep records of the handled waste. They have to establish a working plan for the facility and provide for its implementation; they must publish a list of waste they are authorized to handle, and –generally spoken -manage the facili-ty in a way to secure the environment and the health of workers, neighbours and population. They have to keep records and charge fees foreseen for the services in ordert o cover the full costs. They must designate a qualified responsible person, must care for competent supervision oft he fa-cility and provide (technically and financially) for the future recultivation of the site after its closure during a period of at least 30 years. Ad 2: Improve cooperation and information exchange Perform regular meetings of representatives of the Environmental Ministry with relevant repre-

sentatives of the sector, like Chamber of Commerce, in order to discuss actual developments in the field of waste management.

Cooperation between Environmental Ministry and other Ministries (e.g. Ministry of Labour ) for a better information exchange e.g. concerning inspections results and consequences. This should improve the quality of joint inspections comprising waste management and occupa-tional safety issues.

Better involvement of the Legal Department responsible for Waste Legislation within the Envi-ronmental Ministry into the TWINNING project in order to strengthen the legal framework and facilitate the exchange between legal and technical experts.

Ad 4: Permitting procedure Permits are necessary to perform waste management activities like waste collection, transport, storage, recycling, energetic re-use, treatment and disposal (incineration and landfilling). Such permits can be issued for several of the above mentioned activities. The Ministry shall issue permits to collect, transport, store, treat and dispose of hazard-

ous waste, permits to treat inert and non-hazardous waste by incineration and permits to treat waste within a mobile plant and permits to store, treat and dispose inert and non-hazardous waste on the territory of several local self-government units.

The competent autonomous province authority shall issue permits to store, treat and dis-pose of inert and non-hazardous waste on the territory of several local self- government units within the autonomous province and permits to collect, transport, store, treat, re-covery and dispose of waste for all the activities on the territory of the autonomous province and for all the facilities that apply for the construction permit at the competent authority of the autonomous province.


Local Self-Government Units shall issue permits for collection, transport, storage, treatment, recovery and disposal of inert waste and non-hazardous waste. City of Belgrade shall issue permits for collection, transport, storage, treatment, recovery and disposal of all kind of waste, if construction permit was issued by City of Belgrade.

The introduction of integrated permitting procedures (comprising all aspects of the building, opera-tion and closure of the facility) should be evaluated. A reference to the documentation on the pro-ject should be part of the permit. An update of the Rulebook including templates for permits with minimum requirements in accordance with BAT should be performed. The permits should always refer to the project documentation the permits are based on. Binding minimum standards for the permitting procedure in accordance with the Rulebook should be introduced as well. Two other options are in favour of raising the quality of permits: Option I: All permits ahall be issued by the ministry (except the permits issued by the Auton-

omous Province of Vojvodina). This measure can raise the quality of the permits in terms of comprehensiveness and homogenity. Especially permits for IPPC installations should be granted on the Ministry Level only (except the permits issued by the Autonomous Province of Vojvodina). But for this, the staff of the ministry must be extended to a certain extent. Under certain circumstances the delegation of the permitting procedure could be foreseen to certain self-governmental units (e.g. to the City of Belgrade which has the capacities and knowledge to issue such permits).

Option II: All permits issued by the municipalities could be forwarded to the Environmental Ministry in order to perform a quality check.

Ad 4: Inspection procedure Waste transport inspections on the road are to be carried out by the Environmental Inspectors

in co-operation with the Police; such inspections need to be introduced in the overall Environ-mental Inspection Planning.

In case of inspections on illegal sites, in waste treatment plants and illegal transport a good cooperation between inspectorate and police / ministry of transport must be established. This can be prepared in frame of a Memorandum of Understanding.

Inspections in the frame of the permitting procedures of IPPC installations should be per-formed by participation of both, the permitting authority and the inspectorate at state level. Such joint inspections should be introduced as obligatory.

Jpoint inspections by Labour Inspectors and Environmental Inspectorate should be carried out. Regular meetings should be performed to share experience and plan joint inspections.

Ad 4: Document on waste movement The Document on hazardous waste movement tracks the movements of hazardous waste. It contains all relevant data on the individual transport process from the generator tot he storage or treatment facility with all details necessary to track and control the individual waste movement; these data are most suitable for hazardous waste statistics. The copies of these documents allow all participants to prove the compliance with legal obligations. Close monitoring of hazardous waste flows from generation to final treatment, by implementing a shared IT-system (an electronic data base for any obligatory waste reporting) is desirable. Ad 4: Financing of the waste management activities for the end-of-life products and respon-sibilities During the Twinning project IPA 2008 (Strengthening Institutional Capacity in Hazardous Waste Management) implementation period the Environmental Protection Fund as an institution was abol-ished and replaced by a pure taxation system to the State budget, for products placed on the mar-ket.


Bearing in mind the different approaches used worldwide, two general groups of recommendations were derived, which remain relevant for the future implementation of the EU waste management law in Serbia, namely those requiring legislative measures and those related to the practical implementation.

These measures have to set-up the mechanism of financing the waste sector from the collected amounts , if such fees are applied and to define who shall take the responsibilities for achieving the collection /recycling /recovery

targets subject to producer responsibility requirements. Ad 5: Institutional framework for waste management The institutional framework for waste management comprises the institutional structures and ar-rangements and the organizational procedures and capacities of the competent institutions. This framework includes the following:

division of functions and responsibilities among the local, regional and central authori-ties;

suitable organizational structure of the institutions responsible for waste management, and well adapted coordination procedures between them;

uniform and transparent procedures for planning and management; sufficient capacities of the institutions responsible for waste management and high

competence of the employees; enlarged participation of the private sector.

Ad 5: Decentralisation and division of responsibilities Effective waste management depends on the adequate division of responsibilities, competences and revenues between the central, regional and local governments. Local authorities, respon-sible for municipal waste management, shall manage all the operations concerning the municipal waste, including the financial management oft he operation through collected fees and other rev-enues. An adequate distribution of financial and administrative responsibilities implies management of t h e local budgets for the municipal waste management, based on real costs. Decentralization of municipal waste management implicates more flexible, efficient and responsible attitude on a local level. Such delegation of decision-making, finance management, provision and implemen-tation on a lower levels reduces the administrativeburden on the Ministry, and facilitates to fo-cus on its own competences. Certain municipal waste problems especially in rural area of Serbia need common solutions, oth-erwise waste management gets too expensive and dissipates ressources. Associations of munici-palities shall be necessary in s u c h c a s e s i n order to plan jointly and establish an economi-cally sustainable and rational common management system.


Yet, hazardous waste management shall stay in the responsibility of the Republic and the prov-inces since hazardous waste needs over-reginal solutions and few central facilities and sites. Hazardous waste management is in all MS of EU a matter oft he state; this implies centralized programmes and planning, and universal state-wide harmonized financial management. Provincial authorities will also have certain responsibilities in the area of preparation and implementation of pro-grammes and plans at the provincial level. This statement is not in contardiction to the necessity of private sector engagement in hazardous waste operation and private responsibility in hazardous waste management. Bearing in mind that special waste streams like medical waste, hazardous packaging waste (pes-ticides), and mining waste are under responsibility of other ministries, hazardous waste manage-ment needs intense cooperation with these authorities, in order to manage these waste streams coherently. Ad 5: Administrative resources Additional administrative resources will be needed for the implementation of the strategy and the realization oft he National plan on hazardous waste. This is especially the case for the national level, less on the provincial level and few on the local level. This need primarily pertains to the implementation of necessary legislative, institutional and or-ganisational measures, to the development and supervision of the waste management system and infrastructure and tot he supervision and control of the private sector activities in this field. It can be expected that a certain additional and temporary work-load can be financed by the EU or from bilateral technical assistance programmes. But tasks pertaining to permanent functions will require appropriate resources that must be delivered by re-groupment of administrative re-sources. Ad 6: Planning and management methods In addition to the Waste Management Strategy, it shall be necessary to enact waste manage-ment plans. National plans for specific waste streams shall be enacted in order to manage various

waste streams. Regional waste management plan shall be enacted by local assemblies of two or more lo-

cal self-government units by which they define their joint objectives in waste manage-ment. The procedure of drafting and enacting a regional plan shall be governed by the agreement entered into force between the assemblies of local self-government units.

Local waste management plan shall be enacted by local self-government unit by which it defines the objectives of waste management on its territory.

Waste management plan in IPPC facilities shall be established by the operators of those establishments, as a part of the documentation which is attached to the application for inte-grated permit.

Operational plan for waste management facilities including landfillsshall be established by the operators of waste management plants for which integrated permit or waste man-agement permit is issued.

Due to its nationwide implications it shall be necessary in hazardous waste management – more than in municipal waste management - to establish strategic planning and appropriate financial management, including the real prices of services, control of the budget, calculation of unit costs and comparat iveeconomic analysis. For the operational planning national and regional authorities (and only to a small extent local municipalities) shall be obliged to provide necessary data, deliver analysis of waste composition, assess waste generation, specify necessary equip-ment, provide monitoring, evaluate information from operators and encourage auditing.


Spatial planning and regional development programs play an important role for a successful sustainable waste management planning. Regional planning has so far a key role in hazardous waste management:

It provides the regional or national planning framework that covers all interests and belong-ings and matches the hazardous waste management needs with other political, environ-mental, social and economical needs of the area concerned.

It results from carefull planning processes with regard to natural and environmental con-servation interests;

It protects certain areas and natural reserves from undesirable developments; It minimizes adverse impacts on the environment arising from hazardous waste

management through environmental compensatory measures; It freezes important naturally (geologically) favourable sites for hazardous waste manage-

ment purposes (e.g. Landfills) that now are reverved for such purposes. Ad 6: Indicators for the Strategy implementation Indicators are very important for a successful assessment of decis ions, measures and activi-ties. The number of indicators should be few and must reflects the overall characteristics of the sector, in this case of an appropriate hazardous waste management system. Indicators related to hazardous waste management belong to the so called „ environmental pressure indicators“, because generation and disposal or treatment of hazardous waste generally stress the environment. The competent authorities have defined such indicators and continue to monitore their develop-ment. Liabilities to deliver such indicators regularly to the international institutions help to com-pare and harmonize these instruments on an international level. 10.1.1.3 Market based instruments

Measure Priority Sub-Measure Main Responsibility


Until when

1 Participation of the private sector

H

Promote competitivetenders for provisionof services Decide on public in-centive measures for PPP in HWM servicesDetermine public in-centive measures for new recycling indus-tries


Experi-enced pro-fessionals

2020

2 Transposition of the extended pro-ducer responsibility

H

Monitor the design of new products, Establish instruments of sactioning unap-propriate products Determine payment of fees on products for their waste manage-ment after use


Industry profession-al associa-tions Operators

2020


3 Develop different forms of private sec-tor participation

H

Develop instruments of motivation for pri-vate sector participa-tion Decide on favourable form of private sector participation in every single case

Privat sector, Waste facility operators

Ministry of Environ-ment, re-gional au-thorities profession-al associa-tions

2020

4

Establishment of an infrastructure for hazardous waste by private investment activities

H

Develop instruments of motivation for the investment in HWM facilities Decide on necessary facilities in legally binding plans Determine initial fi-nancial support for covering financial risks Force generators to adopt new appropri-ate facilities


Ministry of Environ-ment, Prov-ince of Voj-vodina, lo-cal authori-ties

2020

5

Install new mecha-nisms to fix opera-tional costs and af-fordable service prices

Implement new method to determineprice of services Improve system ofsupervision, control, imposition of penaltyand collection of fines Establish the systemof extended respon-sibility of manufactur-ers aimed at settingup the system fully compliant to EU Start granting con-cessions to privateand mixed compa-nies, primarily, for ac-tivities of collectionand disposal of waste Perform liberalisationof the sector, intro-duce competition andright of user to choose the most fa-vourable service pro-vider, and deregulateprices Privatise the activitiesrelated to waste management, wher-ever justified


Ministry of Environ-ment, Prov-ince of Voj-vodina, lo-cal authori-ties

2020


Ad 1: Restructuring and transforming the sector for participation of the private sector Participation of the private sector is of a high priority of the Government of the Republic of Serbia. In order to develop competition between the public and the private sector, the Govern-ment needs to take necessary institutional/organisational measures and actions. Private commercial entities can provide the services of collection, transportation and dis-

posal of municipal waste more efficiently, and often also with less costs than the public sector.

Private commercial entities can be interested in providing services of managing specific waste streams.

Private sector can be interested in introducing the technologies of treating certain types of hazardous and non-hazardous waste.

However, the inclusion of private sector in waste management does not guarantee the efficien-cy per se. It shall be necessary to organize a competitive tender for provision of services and efficient supervision of the contract and of the execution of contracted services. It shall be necessary to introduce incentive measures for the participation of the private sector in all domains of managing municipal and hazardous waste and to work on the development of A partnership between the public and the private sector in the context of existing services

and to stimulate the development of new recycling industries.

Ad 2: Transposition of the extended producer responsibility The instrument of an extended producer responsibility for their own products comprizes the obli-gation of producers to design products for long life use, for easy repair and for easy de-composition after use to reduce the use of hazardous substances during production process and in the product to monitor a respective product during its use by the consumer with regard to above

,mentioned items, to take over the product from the consumer when the product lifetime expires, and to forward the product to recycling or re-use.

Responsibility has been established for producers and importers of certain products that, after their use, become specific waste streams, to pay a fee. This fee should be used for the treatment of such products when they become waste. Operators of collection and treatment ser-vices can be remunerated from these financial ressources for their services. It is very important to include competition elements and to liberalise markets of services ren-dered by utility companies. The change in the ownership structure of business entities cannot guarantee an increase of allocation and production efficacy. It is therefore preferable, through contracts granting concession, to transfer rights of performing certain jobs related to waste man-agement to private or jointly-owned companies (public-private partnership). Introduction of competition wherever it is possible is essential for a transformation process. In order to make the sector efficient, it is important to introduce competition in the process of get-ting concessions and to constantly control the behaviour of concession holders. Competition in the struggle to win markets, if fair, may have positive effects on general wellbeing. Various arrangements such as: Design Build Operate: DBO, Build Operate Own: BOO and Build Operate Dispose: BOD may be useful in the field of waste disposal and recycling.


On a long-term basis, a possibility is being introduced for citizens to select the most appro-priate provider of waste collection and disposal services. In this manner competition would be in-troduced not only in the struggle to win markets, but also on the service market itself, and the prices would cease to be the subject of regulation. This would mean that the sector has defi-nitely been liberalised, while the change of the ownership structure of business entities would take place gradually, as a consequence of the liberalisation. Ad 3: Different forms of private sector participation Further development of the waste management sector in the Republic of Serbia requires an in-creased participation of t h e private sector. Generally spoken, the private sector participa-tion in the fields that traditionally were under the control of the public sector may satisfy many objectives:

provision of investment capital, decrease of needs for subsidies, improvement of management efficacy, improvement of technical and management capacities of the local public organization,

etc. It is important to develop instruments that are able to motivate the private sector to improve the quality of their services and the efficiency of their systems. There are numerous forms of the private sector participation and common classifications start from the criteria of investment, ownership and responsibility (risk). 1. The first group includes forms in which the public sector remains the owner of assets

and bears the responsibility related to investments, while risks are divided in a certain pro-portion: The private sector is engaged in performing specific activities. Contracts usually comprise shorter periods of time. The private sector takes on the responsibility for pro-duction- technological function and maintenance of municipal service companies that remain in the state ownership. An essential element of a contract is the degree of transferring the commercial risk to the private sector so that it may be sufficiently motivated to decrease costs and improve the quality of services. Another model is: The private sector assumes the responsibility for operation and mainte-nance of means taken on lease and it buys the right on future money inflows of the company, thus taking the major part of commercial risk. It is often the first step towards a complete involvement of private capital, through concession.

2. The second group, generally called concessions, consists of forms of cooperation where the right of operation is transferred to the private sector on the basis of a contract, while the ownership over existing assets is retained, meaning that after expiry of a certain period, (20-30 years), the means financed by the private sector during the contract term are taken over. A typical arrangement is BOT, usually used for new projects that include facility building (Build), operation (Operate) during a defined period and transfer (Transfer) of own-ership to the public sector after the expiry of the period. In the case of concession, the pub-lic sector has two main tasks – to ensure an adequate use of assets that it owns and, through regulation, to protect consumers of possible monopolistic pricing or low quality services.

3. The third group comprises full or partial privatisation. In the case of full privatisation, the public sector has only the functions of establishing regulations. Facilities are property of the private sector. Partial privatisation projects may include company management by the private sector, but they always comprise the public sector full or partial waiver of the ownership over the property.


Local authorities should encourage private sector participation in order to: Use and improve the technical and management expertise of the services; Enable the introduction of new technologies; Increase the efficiency of services; Create the basis for building up larger capacities of services; Open the way for decrease of public subsidies for services and Improve the quality of services.

Ad 4 and 5: Hazardous waste management and specific waste streams management ser-vices The establishment of an infrastructure for hazardous waste in general and for specific hazardous waste streams (like waste oil, WEEE and ELV) will be carried out through investments of the private sector, the Serbian Development Fund, and International funds, on the basis of permits for such hazardouswaste management activities. The priority should be given to the development of appropriate treatment and diposal facilities for such hazardous wastes arising from end-of-life consumer goods and from industrial activities. 10.1.1.4 Information based instruments


Main Responsibility


Until when

1

Professional train-ing of staff and communication with professionals

H

Acquiring and improving of edu-cation and training of wastemanagers, technologists and op-eration staff: Industrial profes-sionals oriented activities Waste sector oriented activities Administration staff oriented ac-tivities Development and implementationof a programme for continuouscommunication with all partici-pants in waste management,particularly with generators

Ministry of Environment

Experienced professionals

2020

2 Education of future professionals

H

Establishment of state-of-the-art curricula Implication of students in practical works of the sector Establishment of national authori-ty in charge of development ofeducation programmes and train-ing


Universities and High Schools

2020

3 Public awareness raising campaigns

H

Children and youth oriented ac-tivities General population oriented activ-ities Information delivery activities Good and bad practice publishing activities

Ministry of Environment, Local authori-ties

Schools, teachers, in-spectors and professionals

2020

4 Hazardous waste oriented infor-mation campaigns

H

Concerned public oriented activi-ties General public oriented activities Waste sector oriented activities Municipalities‘ oriented activities


Waste sector and experts

2020



Main Responsibility


Until when

Raise public awareness aboutthe necessity and conditions to build regional waste manage-ment plants Public awareness campaign re-garding the benefits of using waste as an alternative fuel and as an alternative raw material

Ad 1 and 2: Staff training and public awareness raising Development of human resources for an appropriate and sustainable hazardous waste man-agement may be divided into three main fields: Professional training of staff (including a training of waste generators); Education of future professionals; Public awareness raising.

The aim of such professionalstaff training, education measures and public awareness raising campaigns is to initiate activities that will: Raise the awareness of the majority of population regarding the environmental issues,

especially of children and youth, creating a background for future activities in the contexte of sustainable waste management;

Ensure adequate technical and professional competence of all levels in institutions and or-ganizations, as well as of all employees dealing with waste issues in industry and admin-istration in accordance with their competences, including private sector companies, with the responsibility of waste management and implementation of law at all the levels.

Ad 1 and 2: Staff training Professional training will be a primary goal in a short-term period so that waste management staff may be technically competent for their work positions. This will include requirements for training of staff in all the companies that deal with waste, as well as of staff who are respon-sible for waste management in ministries or local authorities. Experts in the field of waste management must provide their assistance in establishing education, as well as in the develop-ment of policy and curriculum. Further education is needed for the responsible persons within the companies of the waste management sector; experience is still low in handling of residual waste from production processes. A crucial improvement in waste management would be achieved by introducing techniques and technologies in the education of future professionals who will work in the field of waste. Foreign experts and local specialists should assist universities to adapt their curricula to modern waste management needs. Special attention must be paid to schools. Baisc education and motivation in primary school and more detailed educational contents in secondary schooling will have long-term effects on behaviour of individuals concerning waste management issues.


Ad 1 and 2: Professional training for competent authorities Professional training for competent authorities involves: all authorities issuing permits; they should be trained to improve the quality of the permits in

terms of comprehensiveness and uniformity as well as application of BAT; all inspectors (local and state level) should be trained to improve the background knowledge

concerning waste classification, legal differentiation between by-products and waste, work place security and health issues, technical performance criteria and data processing.

Ad 3 and 4: Public awareness raising Public awareness raising campaigns encourage individual consumers to assist in achieving a sustainable waste management through decreasing waste generation, purchase of products made of recyclable materials, separation of waste for recycling and participation in local work-shops on waste management. These initiatives are aimed at encouraging population to as-sume a more responsible attitude towards waste and to handle waste in a sustainable man-ner, including a waste reduction at the source, reuse of waste, recycling or reliable waste dis-posal if there is no other possibility. Establishing a policy of public awareness raising concerning environmental and waste issues is an duty of the Ministry competent for environment and of regional and local authori-ties.Experienced professionals should assist. All companies oft he waste sector should foresee regular campaigns for raising public awareness for risks of unappropriate and chances of appropriate waste management. It is essential to show to the public the adverse effects of inappropriate waste disposal and the environmental, social and economic benefits of good practice. Public should be informed about the implications of the “polluter pays” principle in terms of reduction of public subsidies and charges for waste manage-ment services. In addition, inspectors and lawyers could play a significant role with a firm mes-sage related to penalties for offenders of waste management obligations. This might help to devel-op trust between state authorities and citizens. The public should participate in the activities and reflections about suitable improvements. Citi-zens must have access to the relevant informations, which has been legalized by the adoption of the Law of Acknowledging the Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (Aarhus Convention). Special attention must be paid to raising awareness for the necessities of a sustainable management of hazardous waste and the necessity for establishing an appropriate infrastruc-ture including facilities and sites for storage, treatment and disposal of such waste. 10.1.1.5 Voluntary instruments and voluntary agreements


Main Responsibility


Until when

1

Examine if voluntary agreements with in-dustrial sectors or single firms can re-place strict legal ob-ligations

H

Study about legal regulations suitable for being accompa-nied or replaced by voluntary agreements


2020

Establish instruments for achieving the goals by sanctions and threats in case of non-fulfillment of con-tracts


2020


In industrial waste management voluntary agreements that replace stringent legal obligations for generators and operators are an important instrument. Such agreements are feasible as long as single industrial firms (big generators), half public-half private institutions (e.g. in mining industry) or associations of tightly organized industrial braches (e.g. pharmaceutical or chemical industry) are concerned. In other cases such agreements are less promising. In EU MS voluntary agreements have been often combined with the threat of subsequent legally binding prescriptions if certain conditions repeatidly have been broken: This might be a minimum target of waste collection or a maximum number of infringements. Voluntary agreements have been used (and later replavced by stricter regulations) in Germany for securing minimum percentage of recyclable glass bottles in the beverage market, and more suc-cessfull for recycling targets of plastic bottles in the beverage market.

10.1.2 Measures concerning hazardous waste streams

10.1.2.1 Measures for hazardous waste management from industry and commerce See above (chapter 10.1.1) 10.1.2.2 Measures for hazardous C&D waste management including asbestos waste Taking into account the current status of asbestos waste management in Serbia the following measures shall be taken in order to achieve the objectives as described in Chapter 0. Regulatory measures / instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

1

Enact the (drafted) by-law covering mineral C&D

waste

H

Considering a) recycling ori-entated dismantling b) source

separation c) storage & transport d) end-of-waste sta-tus e) quality criteria for C&D

waste

MAEP

(for imple-mentation an amendment

of the Law on Waste Man-agement is requested)

End of

Q4/2018

2

Publish the (drafted)

Waste Man-agement Plan for Asbestos-

containing waste

M

Considering the information on a functioning system for the save collection, storage, treatment and disposal of as-bestos waste and asbestos

containing waste

MAEP End of

Q4/2018

3

Make the demoli-

tion/renovation plan manda-tory in the ap-proval proce-

dures for a demolition/de-construction

permit

H

Considering the relevant in-formation on the removal

and/or separate collection of hazardous components and

contaminated fractions

Ministry of Construction, Transport and Infrastructure / Local Au-

thority

MAEP End of

Q2/2018


Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

4

Make the use of recycled

mineral C&D waste obliga-tory in public tendered con-struction pro-jects (Green Public Pro-curement)

M

Considering a) quality aspects b) specific mandatory share (e.g. 10%) to be used in new

public tendered projects

Ministry of Construction, Transport and Infrastructure / Local Au-

thority

MAEP End of

Q4/2018

5

Update the Regulation on procedures of

asbestos-containing

wastes, Offi-cial Gazette of

the RoS, No 75/10

H

Considering that the produc-tion of asbestos is already

banned and the focus should be laid on the handling of as-

bestos containing waste

MAEP End of

Q2/2018

Operative measures / instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

1

Enlarge the administrative

capacity for inspection and punishment of illegal opera-

tors

H

Considering a) ban of illegal dumping b) illegal de-

construction c) illegal trans-portation of (hazardous) C&D waste d) guarantee the exe-

cution of penalties

MAEP, Com-petent Author-ities, Autono-mous Prov-

inces, Ministry of Justice, Po-

lice

Ministry of Construc-

tion, Transport and Infra-structure, Ministry of

Health, Min-istry of La-bour, Em-ployment,

Veteran and Social Af-

fairs

End of Q4/2018

2

Enlarge the mechanical

treatment ca-pacities for

non-hazardous mixed C&D

waste for re-cycling

H

Considering a) the amount yearly generated b) quality standards for recycled C&D

waste (proposal: 4 to 5 facilities in

different cities with each 30.000 to 50.000 tons per an-

no)

Waste man-agement sec-

tor (waste management

operators)

Building sector,

Chamber of Commerce, Competent authorities

End of Q4/2020


Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

3

Guarantee thermal treat-ment capaci-

ties (co-incineration in cement plants) for hazardous

C&D waste

H

Considering a) the amount yearly generated b) at least

waste streams contaminated wood, PCB containing waste



operators)

Building sector,


End of Q4/2020

4

Establish case-related

biological treatment for hydrocarbon-

or PAH-contaminated

soils

M

Considering a) the amount yearly generated b) for low

quality amounts alternatives like physical-chemical treat-

ment or landfilling



operators)

Building sector,


End of Q4/2020

5

Establish ca-pacities for

the disposal of hazardous

waste at sani-tary landfills

M

Considering a) the amount yearly generated b) geograph-

ical spread (even when the total capaci-ties seem to be sufficient – more sanitary landfills with

additional capacities for haz-ardous waste would guaran-

tee a better geographical spread and lower transport

distances)

Local self governmental

units

MAEP, Competent authorities,

Autonomous Provinces

End of Q4/2018


Market based instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

1

Introduce quality stand-ards for recy-

cled C&D waste

H

Considering a) technical as-pects b) environmental as-pects and c) quality assur-

ance schemes

Institute for Standardiza-tion of Serbia

(ISS)

MAEP, Min-istry of Con-

struction, Transport and Infra-structure

End of Q4/2017

2

Establish a representa-

tiveness body for the recy-

cling industry

L

Considering a) technical ca-pacity building b) labelling for recycled C&D waste c) inter-

nal quality assurance schemes

Chamber of Commerce, Waste man-

agement sec-tor (waste

management operators)

Building sector

End of Q4/2018

Informative measures / instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

1

Introduction of measures to col-

lect and keep records of infor-mation on build-

ing materials

M

Considering the materials used for the current stock of buildings and especially for new buildings with a view to

recyclability and selective de-construction

Ministry of Construction, Transport and Infrastructure

Building Sector

End of Q4/2018

2

Share infor-mation on rele-vant regulative and informative

instruments (e.g. via website)

M

Share information on a) rule-book on preventive measures for safety and health at work that exposes to asbestos (Of-ficial Gazette of the RoS, No. 108/15 replacing No. 106/09) b) drafted WMP on asbestos containing waste c) drafted by-law covering C&D waste

MAEP

Labour In-spectorate at the Min-istry of La-bour, Em-ployment,

Veteran and Social Af-

fairs

End of Q4/2017


Measures on voluntary basis

Measure

Priori-ty

Sub-Measure Main

Responsibility

In co-operation

with Until when

1 Agreement on joint inspec-

tions H

Considering a) selec-tive de-construction

according to the dem-olition plan b) waste transports c) man-

agement of asbestos with special regard to

workers safety

MAEP, Labour Inspec-torate at the Ministry of Labour, Employment, Veteran and Social Af-

fairs

Ministry of Construc-

tion, Transport and Infra-structure,

Police

End of Q4/2017

2

Establish Working

Groups on Ministry Level / Association

Level

M

Considering the de-velopment of relevant standards and tech-nical reports for the recovery orientated dismantling of build-ings and construc-

tions

MAEP

Institute for Standardiza-tion of Ser-bia (ISS),

other Minis-try Levels,

Chamber of Commerce

End of Q2/2018


10.1.2.3 Measures for hazardous medical waste management

Taking into account the current status of medical waste management in Serbia the following measures shall be taken in order to achieve the objectives as described in Chapter 0. Regulatory measures / instruments

Measure Priority Sub-Measure Main Responsibil-ity


Until when

1

Defining legal framework for funding of HC waste manage-ment on the basis of polluter pays principle

H

Specify funding regulations in legal framework

Ministry of Health

Ministry of Environ-ment

2020

Introducing sus-tainable funding mechanisms in le-gal framework

Ministry of Health


2020

Integrating funding mechanisms in the reorganisation of the healthcare sec-tor

Ministry of Health


2020


Measure Priority Sub-Measure Main Responsibil-ity


Until when

1

Improve environ-mental assess-ment in permit-ting and enforce-ment procedure

H

Attaching condi-tions to the permits to ensure that envi-ronmental impacts from facilities are minimised

Ministry of Health


2020

Improve environ-mental investiga-tions during permit-ting procedure

Ministry of Health


2020

Improve participa-tion practice in permitting and en-forcement proce-dure

Ministry of Health


2020

Enforcement of compliance inspec-tions of competent authorities

Ministry of Health


2020

2 Acknowledge-ment of Staff

M

Recognise the ef-forts and special risks of the healthcare staff by paying a higher net wage to con-cerned staff mem-bers

Ministry of Health


2025


3

Establishment of an integrated waste manage-ment system for medical and pharmaceutical waste

H

Draft a national program for medi-cal waste man-agement, to define more precisely the quantity and types of medical waste Draft waste man-agement plans in all health care insti-tutions and veteri-nary organisations

Ministry of Health


2020




Until when

1

Provide technical guidelines and training on haz-ardous medical waste separation, labelling, packag-ing and collecting

H

Provide technical guidelines Perform trainings of medical staff with regard to stae-of-the-art handling of HW

Ministry of Health


2020

2 Training H

Essential training courses exist and are exercised, Refresher training shall be introduced for experienced staff members

Ministry of Health


2020

Each healthcare institution has at least one staff member put in place who has successfully at-tended or re-freshed medical waste manage-ment courses

Ministry of Health


2020


3 Awareness Rais-ing

H

Investigate the possibility to in-clude a message on patient infor-mation leaflets in-serted in medicine packaging inform-ing patients about the proper way of disposal Provide internal training to the staff in HCWM, policies and procedures in order to raise awareness

Ministry of Health

Agency for medicines and medical de-vices

2020

10.1.2.4 Measures for hazardous waste management from households Taking into account the current status of hazardous waste management from households in Serbia the following measures shall be taken in order to achieve the objectives as described in Chapter 0. Regulatory measures / instruments



Until when

1 Regulations con-cerning financing of municipal HW collection activi-ties

M Ministry of Envi-ronment

Units of self-government

2025





Until when

1

Installation of col-lection of hazard-ous wastes from households

M

Manage planning activities Manage site selec-tion procedures Manage construc-tion works and equipment Build „recycling yards“ in urban areas equipped with compartments and instructed staff for the collection and for labelling of harzardous waste from households.



2025

2 Decide on collec-tion modalities

M Decisions about stationary or mo-bile collection,

2025

3 Manage the transport of col-lected HW frac-tions

M

Holding contracts with several re-gional HW trans-porting firms



2025




Until when

1 Awareness Rai-sing

M Information cam-paign for house-holds



2025

2

Provide technical guidelines and training on HW separation, label-ling, packaging and collecting

M

Provide technical guidelines Perform trainings of municipal staff with regard to stae-of-the-art handling of HW

Ministry of Envi-ronment


2025

3

Training courses for municipal workers

M

Learning general operational logis-tics of HW facilities Learning storage techniques of HW Learning transport regulations and la-belling of HW



2025


10.1.2.5 Measures for hazardous packaging waste management

Taking into account the current status of hazardous packaging waste management in Serbia the following measures shall be taken in order to achieve the objectives as described in Chapter 0. Regulatory measures / instruments



Until when

1 Regulations con-cerning responsi-bility and financ-ing of hazardous waste collection activities

M

Decide on organi-sation of the collec-tive schemes Decide on the fi-nancing of the sys-tem


CoC, Indus-tries

2025

2 Establish con-tracts between potential collec-tive schemes and the Ministry


CoC, Indus-tries

2025




Until when

1 Installation of a collective scheme for hazardous packaging waste from agriculture and industry

M

Establish contracts with appropriate transport firms about transport modalities

Collective schemes

CoC, Transport firms

2025

2 Decide on collec-tion modalities

M Decisions about the pick-up system,

Collective schemes

CoC, Transport firms

2025

3

Manage the treatment oportu-nities for the waste collected

M

Contract treatment facilities Organize export modalities if nec-essary Establish industrial treatment options

Collective schemes

CoC 2025





Until when

1 Awareness Rai-sing

M

Information cam-paign for agricul-ture and industry for separation at source and collec-tion of hazardous packaging waste

Collective schemes

CoC, Ag-ricultural organisa-tions

2025

10.1.2.6 Measures for waste oil management

Taking into account the current status of waste oil management in Serbia the following measures shall be taken in order to achieve the objectives as described in Chapter 0. Regulatory measures / instruments



By when

1

Define the waste oil management system in Serbia

H

Specify, which coordina-tive and organizational tasks have to be cov-ered by the “manage-ment system” for waste oil Decide and define which entity will run the waste oil management system Lay down rules for the taking over of responsi-bilities* regarding the management of waste oil and oil wastes from producers to the man-agement system


P/I, CoC, Mun., man-agement system

when amend-ing LWM

2

Describe the frame-work for the financial organization model for the management sys-tem

H

Define the requirements related to transparency of financial flows e.g. which information has to be published in the an-nual report of any man-agement system; Define the requirements related to calculation of fees by any manage-ment system which has to be notified to and ap-proved by MEMSP


management systems, treatment operatorsP/I CoC

2020



Main Responsibility


By when

Adapt the modalities of financing the cost of management of waste oil necessary for envi-ronmental sound man-agement of oil wastes

3 Manage the registra-tion of produc-ers/importers of oils and lubricants

H Ministry of Trade, Ministry of Environment

CoC, Minis-try of Econ-omy

2020

4

Define the responsibil-ity for achieving the collection rates as de-fined in this waste management plan

H

Lay down that the over-all responsibility for achieving the collection targets has the MEMSP


2020

Lay down that the indi-vidual fee-collectors of a waste oil management system have to contrib-ute to the collection tar-get proportionately to their market shares


management system

2020

5

Specify minimum in-tervals for inspection

H

Foresee yearly inspec-tions regarding generat-ed amounts of waste oil and oil waste and their flows


EI when amend-ing LWM

6

Add additional penalty provisions in the LWM

H

Add penalties for those who do not hand over waste oil and other oil wastes to licensed per-sons (keeping records)


when amend-ing LWM

7 Require regular main-tainance of oil separa-tor equipment where prescribed and to hand over the oil wastes to licensed companies

H

Add penalties for those who do not maintain their equip,ment correct-ly and those who down’t hand over the waste oil correctly


when amend-ing re-spective law

8 Determine limit values for waste water dis-charged to sewer sys-tems

H

Decision on self-monitoring by the emit-ting facility and on regu-lar control activities by the waste water system operator (municipality)


Mun

when amend-ing re-spective law

9 Prescribe the use of biodegradable lubri-cants for loss-lubrication in certain fields

H

Related concepts for forestry, agriculture, mining and infrastruc-tural services


CoC when amend-ing LWM





By when

1

Intensify inspection of (potential) waste oil generators, of plants/companies po-tentially treating waste oil illegally and/or non-compliant with tech-nical, of licensed waste oil collec-tors/transporters and treatment plant opera-tors requirements

H

Establish a comprehen-sive database on poten-tial waste oil generators (including industry, petrol station, workshops, etc.) Perform at least annual inspections: - regarding the fate of the generated waste oil - on businesses / plants, which might treat waste oil illegally (brick indus-tries, small burners, etc.)- regarding collection of oil waste* (e.g. existence and maintenance of oil/water separators, etc.) Provide sufficient inspec-tion capacity (indication for needed efforts for in-spection: 1-2 hours per generator)

SEPA, EI Ministry of Envi-ronment, Voj, Mun.

EI, CoC, Min-istry of Envi-ronment, Voj., Mun SEPA

2020

2

Evaluate results of the intensified inspection and activities

M

Analyse: number of cas-es of incompliance, type of incompliance, penal-ties imposed, other measures taken


EI, Mun. 2025

Adapt the inspection in-tervals


EI 2025

3

Analyze lubricant con-sumption and waste oil generation by individ-ual industry branches

M

Specify how to collect and analyse the infor-mation on oils/lubricants consumed and waste oil generated by particular industrial activities (in-cluding e.g. data on waste oil generation re-ported to SEPA by in-dustry)


,Section for Economic In-struments in the Ministry of Environ-ment, SEPA, CoC, univer-sities

2025

Announce a study on mineral oil / lubricant consumption and waste oil generation by differ-ent industrial activities

management system


2025

Formulate quantitative prevention goals for indi-vidual industrial activities

CoC Ministry of Environment

2025



Main Responsibility


By when

4

Evaluate the waste oil collection results and analyse the amounts of waste oil used by the informal sector

M

Analyse - waste oil generation amounts reported to SEPA - amounts treated in li-censed waste oil treat-ment plants - database on waste movement documents

SEPA

Ministry of Environment, EI, manage-ment system

2025

Publish the results (col-lection and details about treatment) in SEPA re-ports on special waste streams

SEPA Ministry of Environment

continu-ing

Continuing evaluate the collection results


CoC continu-ing

5 Establish sufficient collection facility in ur-ban and rural areas for waste oil from house-holds

H Establish certain number of waste oil collections facilities

Mun. managemen system

2020

6

Establish waste oil col-lection infrastructure at all regional waste management centres

H

Evaluate the perfor-mance of the collection system for separate col-lection of waste oil from households Establish waste oil col-lection infrastructure at all regional waste man-agement centres being projected

Reg., Mun. managemen system

2020

7

Collect and compile information on real costs for waste oil management in Serbia

H

Collect and compile in-formation on real costs for individual steps of waste oil management in Serbia (collection containers, facility equipment, transporta-tion containers, trans-portation, costs for pre-treatment, disposal costs for residues, awareness raising) and revenues from waste oil

CoC

Ministry of Environment, treatment operatorspu-blic utility companies Inspectors

2020

8

Ensure that sufficient capacity for the (pre-) treatment of all types of oil wastes is in-stalled

H

Determine the required CP-treatment capacity


SEPA, Voj, Mun., Indus-try, CoC

2020

Determine and specify the option of giving sub-sidies for building CP-plants or required miti-gation technology for existing treatment instal-lations by the EPF


managemen system

2020



Main Responsibility


By when

9

Specify technical re-quirements for CP-treatment of oil wastes

H

Determine requirements of the recycling industry Determine appropriate technology of PCT to be applied

MEMSP

Department for Chemi-cals in the Ministry of Environment

2020




By when

1

Provide waste oil owners with relevant information e.g. on types of waste oils and other oil contain-ing wastes, on collec-tion, storage and pre-treatment options

H

Relevant stakeholders with specific information needs are: Producers/importers Automotive sector Retailers Treatment plant opera-tors Instruments are perform seminars promotion in the internet (websites) Prepare and distribute folders, brochures

management system

CoC, Minis-try of Envi-ronment, EI, Universities

con-tinously

2 Perform trainings for IE related to inspec-tion of potential waste oil generators, waste oil collectors and waste oil treatment plants


EI, CoC, SEPA

continu-ing

3

Provide municipali-ties/ public utility ser-vices and operators of regional waste man-agement centres with information on legal background

H

Related informations are in particular tech-nical requirements for collection facilities, need of reporting & info on reporting, penalties to be expected in case of incompliance, etc. to collection facilities Distribution via email, in the internet (websites of SEPA, EPF or other “management system”, MEMPS, regions) and using folders

management system


2020


4

Specify the responsi-bility to perform in-formation and aware-ness building

H

Specify the institutions, which are responsible for performing particular information activities Specify the responsibil-ity to finance the infor-mation measures


management system

2020

10.1.2.7 Measures for waste from batteries and accumulators management Taking into account the current status of waste from batteries and accumulators management in Serbia the following measures shall be taken in order to achieve the objectives as discussed and agreed with the representative of the MEMPS and within Workshops with stakeholders and as de-scribed in Chapter 0. Regulatory measures / instruments



Until when

1

Adopte and implement the relevant articles of the Law on Waste Management and/or the relevant Regula-tions (GO’s) and the MO on batteries

H

Adopte the relevant arti-cles Implement the existing provisions already fore-seen


2020

2 Improve definitions

H

Definition of batteries and accumulators Definition of re-use versus recovery and/or recycling; provide information mate-rial for all stakeholders about this.


2020




Until when

1

Improve registration of producers and import-ers, their control and related data

H

Improve registration of pro-ducers and importers and re-lated data and reports Control market input of prod-ucts and data and reports Establish market based in-struments / economic instru-ments


SEPA 2020


2

Define and implement management systems for batteries and ac-cumulators

H

Define management systems for batteries and accumula-tors Organization models and real cost approach


2020

3 Define and implement collection targets and collection system

H

Create collection system for batteries and accumulators Establish system of points of delivery e.g. collection points or pick-up services Create system of documen-tation of collected amounts


2020

4

Develop concepts for financing of collection and transport

H

Manage financing of collec-tion and transport Develop system of evaluation


2020

5 Start storage and treatment facilities planning

H

Preparing the choice of oper-ators and related permitting procedures Concept and planning for in-terim / small scale storage of portable batteries and accu-mulators Plan additional capacities for storage of automotive batter-ies Planning of treatment of bat-teries and accumulators (sort-ing plant) and concept for fur-ther treatment and disposal of sorting results. Find solutions for the final disposal, recycling or export of sorted fractions Create a sorting plant for the treatment of batteries and ac-cumulators Financing of storage and treatment system


2020





Until when

1 Information and awa-reness building

M

Activities for encouraging separate waste collection; Develop information about waste management sys-tems in general and im-portance of batterie sepa-ration; Perform educational and awareness raising pro-grams waste management issues and the relevance of portable batteries.


Collective schemes

2025

2

Information based in-struments / public re-lation

M

Provide information sheets and/or folder with good examples for end users, children and adults; public enterprises, business and municipalities; Establish collection and in-formation campaigns for portable batteries Provide containers in schools and public build-ings combined with man-agement of separate col-lection services for such containers; Provide containers at fairs, congresses combined with any information posters and folders and/or face-to-face information.

Collective schemes Ministry of Environ-ment

2025


10.1.2.8 Measures for WEEE management

The following measures will be taken in order to achieve the objectives for WEEE as described in Chapter 9.5.7. Regulatory measures / instrument



Until when

1 Define the WEEE man-agement system

H

Determine the structure of the collective schemes in combination with a clear-ing house


2020

2 Lay down the tasks of the chosen manage-ment system

H

Describe and determine the transition of legal re-sponsibilities regarding the management of WEEE from producers to the col-lective scheme


2020

3

Decide which entity will run the WEEE management system in Serbia

H Ministry of Envi-ronment

2020

4

Supervise the coordi-nation and organisa-tion tasks of the new collective scheme

M

Coordinate producers/ im-porters activities (e.g. la-belling), Coordinate & provide in-formation of/for end-users, awareness raising, Provide a minimum collec-tion scheme Coordinate & finance the transport Coordinate & finance treatment of WEEE, Assure that requirements regarding WEEE-treatment are fulfilled Collect data on market in-put, amounts collected and amounts treated Report collected data to different authorities


Collective schemes

2025


5 Supervise the financial caracteristics of the new collective scheme

M

Supervise the framework for the financial organiza-tion model in the law and relevant by-laws. Supervise the application of a real cost approach; Supervise the application of the principle of non-cross-financing between different waste streams; Define the requirements related to transparency of financial flows;


Collective schemes

2025





Until when

1 Collect and compile in-formation

H

Information on real costs for individual parts of WEEE management Information on real costs for collection containers, facility equipment, trans-portation containers, transportation, treatment Evaluate the collection re-sults and prepare annual reports

Collective schemes Ministry of Environment

2020

2

Establish collection facility infrastructure in urban and rural are-as

H

Collection schemes for ur-ban areas Collection schemes for ru-ral areas Integrate the informal WEEE/ scrap collection sector into official WEEE collection schene if possi-ble Establish collection points at regional waste man-agement centers Provide equipment for WEEE collection at small and large municipal collec-tion centers and regional waste management cen-ters

Collective schemes Ministry of Environment

2020

3 Perform inspections of treatment plants

M

Foresee annual inspec-tions of treatment plants Perform trainings and co-ordinate local inspectors Establish and publish a list of approved & accepted treatment operators for export of WEEE


Collective schemes

2025

4

Foresee to register producers and im-porters for the differ-ent categories of EEE

M

Adapt the national register Provide the option for the producer/importer to sim-ultaneously register for EEE and other products


Collective schemes

2025


5

Install a quality assur-ance system of market input reporting

M

Combine reporting of amounts of market input data with calculation of fees to be paid Perform controls of EEE placed on the market Take random samples to check the labeling of EEE Withdraw EEE not labeled or containing hazardous sub-stances from the market

2025




Until when

1

Develop and operate information based in-struments and public relation

H

General information on the legal background, about possibilities to deliver WEEE etc. in the internet, on TV, in local newspa-pers at events in public e.g. municipalities, Targeted information of all stakeholders (collectors, producers, etc.) Provide producers /importers, operators and retailers and municipalities with information on legal background, need of reg-istration & info on registra-tion, need of reporting & info on reporting, penalties

Collective schemes


2020

2

Provide technical guidelines and training on WEEE separation, collection and treat-ment

H

Provide technical guide-lines about proper de-pollution of WEEE to treatment operators, Perform trainings of treat-ment staff with regard to proper de-pollution treat-ment of WEEE


Collective schemes

2020


10.1.2.9 Measures for ELV management

Regulatory measures / instruments

Measure Priori-

ty Sub-Measure

Main

Responsibility

In co-operation

with Until when

1

Enact the (drafted) by-law covering the manage-ment of ELV

H

Enact the proposed amendments of the Law on Waste Manage-ment;

Enact the drafted by-law on the management of ELV;

Enact the proposed amendment of the Decree on products which become special waste streams upon their use.

MAEP

Autonomous Province

Voivodina, local au-thorities

2018

2 Introducing of EPR schemes

for ELV H

Amend the national legislation re-lated to the management of ELV

MAEP

Working group con-sisting of relevant

stakeholders

2018

3

Adoption of the WPP

H Develop the draft of Waste Pre-vention Programme through the Twinning project SR 13 IPA EN 04 16, Support in Waste Man-agement Policy.

MAEP Twinning

project

2019

4 Introduction of

financial in-centives

M

Amend the national legislation re-lated to the management of ELV for introduction of financial incen-tives at national level (a fix amount of money paid to the final owner) to surrender ELV only to authorized collection or disman-tling facilities.

MAEP

Working group con-sisting of relevant

stakeholders

2019

5 Establish a Landfill tax

M

Amend the national legislation on waste management in order to introduce a Landfill tax for dis-posal of shredder residues.

In order to be economic viable, the landfill tax shall be introduced in a period of time (3 years for example) in order to let the in-dustry to organize alternative so-lutions for treatment of shredder residues.

If not the tax will increase the costs of ELV management.

MAEP

Working group con-sisting of relevant stake-holders

2019




Main

Responsibility In co-operation

with Until when

1

Establish an integrated system for collection, storage, treatment, re-cy-cling/recovery/reuse (spare parts) of ELV.

H

An adequate number of au-thorized collection facilities shall be made available for the citizens and covering all the country’s territory.

Automotive pro-ducers and recy-cler & recovery operators

MAEP & local authorities

2020

2 Adoption of the NWMS and NWMP

H

Develop the draft of National Waste Management Strategy (targets) and National Waste Management Plan through the Twinning project.

MAEP

Twinning pro-ject

Working group consisting of

relevant stake-holders

2018

3

Enlarge the administrative capacity for inspection and enforcement

H

Capacity for inspection and enforcement in MAEP;

Capacity for inspection and enforcement in Autonomous Province;

Capacity for inspection and enforcement in local authori-ties.

MAEP Local Authori-ties, Autono-

mous Province 2020

4

Use of best available technologies for ELVs recy-cling and re-covery pro-cesses

H

Use BAT for achieving the ambitious target for ELV’s re-cycling and recovery;

Energy recovery for ASR

Recycler & re-covery operators

MAEP, other competent au-

thorities 2018


Information basedmeasures / instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility In co-

operation withUntil when

1

Awareness raising cam-

paigns on col-lection and treatment of

ELV

H

Initiate and conduct aware-ness raising campaigns on collection and treatment of

ELV for different target groups (professionals, the

wide public, local authorities, etc)

Private stake-holders as ve-hicle’s produc-ers/importers

(or professional associations)

ONGs

MAEP, SEPA, local authori-

ties 2018

2

Improve the reporting sys-tem in order to have reliable data on the

management of ELV

H

Collection of data through all available sources/channels

Crosschecking of data re-ported

SEPA

Local authori-ties, APV,

Economical operators

2018

Market basedmeasures / instruments

Measure

Priori-ty

Sub-Measure Main

Responsibility In co-

operation withUntil when

1

Ensure that auto-motive manufacturers provide dis-mantling in-formation on components and material

H

Ensure that automotive manufacturers provide dis-mantling information on components and material for treatment operators to pro-mote the environmentally sound treatment of ELV’s, safely and economically. The IDIS system (Interna-tional Dis-mantling Infor-mation System) may be used for this purpose.

Ensure that treatment op-erators are using IDIS sys-tem.

Producers

Component manufactures

MAEP/other relevant insti-

tutions 2017

2

Establish a representative body for the recycling in-dustry

M Undertaking of all legal

measures

Automotive produc-

ers/importers

Chamber of Commerce

2018

3

Discounts for the buyers who surrender ELV only to authorized collection or dis-mantling facilities

Undertaking of all legal

measures

Automotive produc-

ers/importers

MAEP/Environmental Fund

2018


10.1.2.10 Measures for the PCB and POP management (Stockholm Convention)

On the basis of the updated inventories that provide insight into the management of POPs in the Republic of Serbia, action plans for the implementation of the updated NIP (Source: NIP report 2015/2016) have been established within the POP’s management project, problems have been identified and priorities for solving these problems have been set up. Nine action plans have been developed: Action plan for institutional and regulatory measures aimed at Stockholm Convention implemen-

tation and reporting,

Action plan for dealing with POPs pesticides,

Action plan for dealing with PCB,

Action plan for unintentionally produced POPs chemicals,

Action plan for dealing with PBDEs, HBB and HBCD,

Action plan for PFOS,

Action plan for contaminated sites,

Action plan for monitoring and research of POPs chemicals and

Action plan for implementation of the Strategy for public informing, awareness raising and edu-cation about POPs chemicals.

Financial implications of all proposed activities in action plans with the methodological review have also been presented. Following activities for solving identified problems in the management of POPs in the Republic of Serbia were defined within the framework of the action plans: Strengthening the present institutional capacities in order to improve national regulations, as

well as their application, for implementing the Convention more effectively.

Strengthening the institutional capacities to improve the system for continuous reporting con-cerning the measures undertaken to reduce POPs in the Republic of Serbia.

Establish an appropriate system for reducing emission and releases of unintentionally produced POPs chemicals into the environment.

Continuing to identify and mark equipment containing PCB >50 ppm with the aim to establish a complete database of PCB equipment.

Identification of products and waste containing PBDEs, HBB and HBCD chemicals and waste containing PFOS chemicals in order to establish a system for proper management of such products and waste,

Preparation works to properly dispose, i.e. to decontaminate PCB containing equipment with the volume larger than 5 dm3 and PCB concentrations above 50 ppm, and to safely dispose identi-fied PCB.

Preparation works for the establishment of a system for safe storage and treatment of chemi-cals, and products containing PBDEs, HBB and HBCD and waste containing PFOS chemicals with the aim to strengthen capacities for the recycling and for treatment of such waste.

Provide regulatory, institutional and technical conditions for identifications, prioriation and reme-diation of areas contaminated by POPs.

Provide information for decision makers, public and international organizations about presence of POPs chemicals in the environment through adequate monitoring and organised system of collecting information and reporting.


Carry out regular systematic monitoring of POPs chemicals within established monitoring pro-grams (old POPs chemicals).

Improve work of laboratories for measurement of POPs chemicals, especially new POPs, through accreditation of methods, procurement of laboratory equipment and training of laborato-ry employees.

Improve national capacities for scientific and research development in the field of POPs chemi-cals.

Regulatory Instruments

Classification of POPs-containing wastes

As mentioned in chapter 4.1.2, the European List of Wastes determines two ways for the classifica-tion of POPs-containing wastes as hazardous:

Use of the limit values determined in Annex IV of the Regulation 850/2004; this way is only fore-seen for certain POPs (PCDD/PCDF, DDT, Chlordane, HCH including Lindane, Dieldrin, Endrin, Heptachlor, HCB, Chlordecone, Aldrin, PeCB, Mirex, Toxaphene, Hexabromobiphenyl and PCB),

Use of the general chemical’s classification of POPs and derivation of assigned limit values from the Directive 2008/98; this way is foreseen for all other POPs (PBDE, PFOS, endosulfans, hex-achlorobutadiene, PCN, SCCP, HBCD and all future new POPs like PCP).

The determinations of the European List of Wastes are required to be transformed at least into the Serbian Legislation.

But on the other hand, an alternative and exceeded transformation for all POPs is possible and shall be taken into account. This exceeded transformation means to use the limit values according to Annex IV of the Regulation 850/2004 for all POPs and not only for these POPs mentioned in the European List of Wastes. The advantages would be that

the classification could be done according to unique criteria

the more stringent limit values according to Regulation 850/2004 would be used

the supervision and control of POPs waste streams would be possible because of the obligatory duty to notify the intended disposal way in advance and to carry transportation forms.

There is no reason why the waste classification for some POPs should be based on the stricter lim-it values of the Regulation 850/2004 and for some other POPs should be based on the less strin-gent limit values of the general waste classification. In this case, the exceeded transformation needs to be notified to the EU.

But there are also disadvantages. The exceeded transformation means that all future new POPs (e.g. PCP) lead to the immediate classification of wastes containing these POPs as hazardous without exception and without transitional period.

Furthermore, all plants intended for the disposal of POPs-containing wastes shall obtain the licence to take over and to treat the relevant hazardous waste. If the plant was allowed only to dispose the relevant non-hazardous waste, then the licence shall be adjusted and extended to the relevant hazardous waste (addition of waste code to the licence within a licencing procedure).


Waste water cleaning

POPs are partly relevant in sewage sludge, especially if the POPs have only an adhesive surface connection to the product where it was used. Some activities are possible in the connection with the legislation on waste water treatment, e.g. the determination of substances of special concern, the determination of limit values or the regulation of the use of sewage sludge.

PBDE can be found in waste water caused by cleaning and rinsing processes and the waste water treatment represents a sink for the degradation of PBDE-concentration in waste water, so the PBDE can be found in the sewage sludge. In order to get relevant data for the qualified determina-tion of a proper limit value above the determination limit value, it is recommended first to measure PBDE content in waste water treatment plants. The second step should be the determination of a strategy to decide whether such a limit value is needed for Serbian because of the relevant exist-ence in sewage sludge and when, what level shall the limit value get considering the further dis-posal ways of the sewage sludge. If it is used as a fertiliser, the relevant limitation according to the legislation on soil protection shall be taken into account.

The same operating principle can be stated with PFOS. The concentration in waste water is caused by cleaning and rinsing processes in metal, paper and textile industry. Also private house-holds are sources for the presence of PFOS in waste water because PFOS is part of much com-mon products. In the same way as PBDE, also PFOS can be found after the waste water cleaning in the resulting sewage sludge. If it is intended to use the sewage sludge as fertiliser in agriculture, forest and gardening, the limit value for PFOS in sewage sludge should be determined with 100 µg/kg28.

In order to avoid the transportation of POPs (and other pollutants) from waste water into the cleaned water, the ability to hold back the pollutants within the sewage sludge is important. Besides the traditional biological and physical treatment of waste water, further processes with special treatment shall be taken into account in order to increase the rate of separation of all pollutants. Membrane filtration, ozone treatment or the treatment with activated carbon are just some samples for additional process steps in waste water cleaning.

In addition, a monitoring of all waste water treatment plants is recommended if sewage sludge is usually used a fertiliser. Not only the two POPs mentioned above are relevant for sewage sludge but also other – organic and inorganic – pollutants.

Finally, it shall be taken into account to phase out the immediate use of sewage sludge as fertiliser. Alternatively, the thermal treatment would destroy any organic pollutants and would transfer any inorganic pollutants to filter dust which is subject to a safe landfill. Treatment operations aiming to extract the phosphorus components for the fertilising purposes are under development.

Electric and electronic equipment

The transformation of the European legislation on waste of electronic and electrical equipment into the Serbian legislation should encompass approaches to address new POPs contained in electrical and electronic equipment (EEE) and their wastes. The mainly used POPs in such equipment are flame retardants like PBDE and Hexabromobiphenyl which are regulated in the Directive 2011/65/EU.

28 Umweltbundesamt: Per- und polyfluorierte Chemikalien; Dessau-Roßlau, 2009;

https://www.umweltbundesamt.de/sites/default/files/medien/publikation/long/3812.pdf


This Directive shall be implemented into the Serbian legislation as soon as possible in order to fulfil the minimum European requirements on the restriction of the use in electrical and electronic equipment. These regulations comprise duties of producers, importers and dealers to place electric and electronic equipment on the market including the labelling and the proof of conformity with the legal requirements, It shall be checked whether the implementation into the national legislation shall be extended on additional POPs like HBCD, PCN and PFOS which are partly used in electric and electronic equipment, too. In this case, proper limit values shall be discussed and derived for legal purposes.

The international (Basel Convention) and European legislation (Regulation 1013/2006) on the transboundary movement of wastes comprise many requirements like the prior notification of an in-tended movement and the supervision of movements and plants. Despite this, the export of wastes of electric and electronic equipment (in general and especially containing POPs) displays an ad-ministrative problem: E‐waste is sometimes declared as new product when exported in order to cir-cumvent existing notification mechanisms.

The new WEEE Directive 2012/19/EU entered into force on 13 August 2012 and became effective on 14 February 2014. According to this, Member States shall ensure that shipments of used EEE suspected to be WEEE are carried out in accordance with the minimum requirements in Annex VI and shall monitor such shipments accordingly. These requirements comprise

a copy of the invoice and contract relating to the sale and/or transfer of ownership of the EEE which states that the equipment is destined for direct re-use and that it is fully functional;

evidence of evaluation or testing in the form of a copy of the records (certificate of testing, proof of functionality) on every item within the consignment and a protocol containing all record infor-mation according to point 3;

a declaration made by the holder who arranges the transport of the EEE that none of the mate-rial or equipment within the consignment is waste as defined by Article 3(1) of Directive 2008/98/EC; and

appropriate protection against damage during transportation, loading and unloading in particular through sufficient packaging and appropriate stacking of the load

and shall be transformed into the Serbian Legislation and have to be implemented into the adminis-trative procedures.

Operative instruments

Governmental funded disposal

Some POPs are part of stockpiles, especially outdated pesticides. These stockpiles are partly known and can be traced and supervised by the authorities. The main problem on dealing these stockpiles is that the owners of the wastes are not able to finance the proper disposal of outdated pesticides including POPs pesticides. To solve this problem, the government could offer a concert-ed action in order to collect and to dispose (destroy) all POPs pesticides. To realise this, a benefi-ciary by the government or by the competent administration is needed.

Such a concerted activity would have some advantages:

unknown stockpiles could be detected because the relevant owner/enterprise wants to partici-pate from this governmental/administrative offer,

an entire and immediate solution of the situation with stored POPs pesticides could be reached,

the selected and contracted waste treatment operation, probably for incineration, could be of-fered for minor costs because of the higher amount of POPs pesticides compared with single disposal activities of each single waste owner,


the inspection concerning the storage sites would be possible and could be decreased after fi-nalising the activity,

the activity could be expanded on other outdated pesticides without POPs.

The concerted action and the relevant beneficiary should cover all steps from identification and analysis, if needed, of POPs-pesticides, new and proper packaging to avoid leakages and to pre-pare for the final disposal, formal waste declaration, notification and control procedure, the final disposal itself, the cleaning of contaminated sites and former packaging material as well as the public communication in advance and after finalisation of the activity.

Alternative, a partly support of a concerted action is thinkable, e.g. in order

only to package the POPs pesticides in a proper way for the future final disposal,

to collect all POPs pesticides in a proper temporary storage unit

to remediate contaminated sites in order to use them for alternative purposes.

To strengthen the detection, inspection

The extent of the presence of POPs, especially new POPs in products, wastes and environmental media is not sufficiently understood. Monitoring measures and the building of inventories are re-quired to fill this information gap. Inventories are required according to legal provisions for some POPs, especially PCB. It shall be enforced that these obligatory inventories are amended and maintained continuously by measures of inspections by the competent authorities. The establish-ment of an overall inventory is a process which needs years and decades an cannot be expected at an early state of decision making.

Further inventories for POPs shall be established in connection with the amendment of the National Implementation Plan according to the Stockholm Convention.

There is an additional need to be able to identify new POPs in articles and products that are im-ported into countries. The following strategies and measures should be considered:

to develop the capacity of customs authorities to identify POPs and articles containing POPs, through increasing technical capacity and human resources in customs offices and through col-laboration at the regional level,

to implement of a control system on the market level in order to supervise the legal require-ments on the ingredients and compartments of products intended to be placed on the marked.

For the inspection purposes, easily practicable test methods shall be available in order to detect POPs or at least chemical elements which allows to conclude the possibly existence of POPs. Such a detection procedure is not only useful in the subject of inspection of waste treatment plants or production sites but also in case of inspection of contaminated sites, of supervision of environ-mental media and the marked control. Furthermore, such fast test methods are suited to decide whether a waste is probably contaminated with POPs at all, e.g. in case of HBCD containing or not HBCD containing insulation material if the labelling does not allow a clarification.

The X-ray fluorescence spectroscopy seems to be suited for these purposes. The competent au-thorities shall be equipped with a certain number of XRF-spectroscopy devices according to the es-timated needs in Serbia, which depends on the scope and the number of intended tests. It is rec-ommended to share the use of XRF devices according to a plan which shall be established by the Ministry/SEPA and which includes the inspection aims on every administrative level.


The XRF allows a fast qualitative check if any elements can be expected within the examined waste, e.g. the content of chlorine or bromine as indication for the presence of POPs. But for quan-titative waste checks laboratory devices are needed like

Gas chromatography–mass spectrometry (GC-MS)

Liquid chromatography–mass spectrometry (LC-MS, or alternatively HPLC-MS).

Uncontrolled technological processes and processes that do not fulfil the state of the art have the biggest contribution to the unintended emission of POPs into air, water and soil. This situation can partly be prevented by avoiding burning dumpsites, open fires or the uncontrolled incineration of wastes in small incineration plants within households. Therefore, the control by the competent au-thorities is essential. The competent authorities shall focus their supervising activities on these facts.

To decrease the unintended release of POPs from technical installations, it shall be transformed and realised the approved and legally required state of the art which is determined within the IPPC regulatory.

Establishing monitoring

Some POPs are relevant for the unintended release into the environmental media. The causal rea-sons can hardly be managed or avoided. But the comprehension of the distribution of POPs in and between the environmental media can be increased by monitoring measures. Therefore, the data basis on POPs in environmental media shall be created and to be amended continuously. Relevant sectors to monitor the presence and the amount of POPs are:

soil in agriculture, forest, urban areas, pasture areas, free landscape,

water of lakes and rivers including their sediments and sediments from flooded areas

precipitation, air and dust particles

farm animals, game, deer, boar, venison and meat including offal, fat tissue

fish and seafood

poultry and eggs

animal feedstuff.

Soil and sediments represent the main sink especially for unintentionally released PCB and PCDD/PCDF caused by the lipophilic characteristic and the adsorption on organic soil compart-ments. But the POPs-containing particles can be mobilised by soil erosion, flooding, wind and can expose agricultural crops and feeding crops. This situation can get worse in case of fertilisation with organic material which was prepared by using wastes (compost, sewage sludge).

A systemic assimilation of POPs by plants can be excluded, but the assimilation by animals by grazing or animal foodstuff is very likely (lipophilic). On this way, the pollutants reach the human foodstuff and endanger the human health29.

In order to get an overview about status and modification/change of POPs-content in environmental media, a strategy shall be developed together with research institutes and universities considering the right sites for an environmental monitoring (potential sources and polluted areas as well as nat-ural sites).

29 Umweltbundesamt: Expositionsbetrachtung und Beurteilung des Transfers von Dioxinen, dl-PCB und PCB - Literaturstu-

die; UBA-Texte 57/2011; Dessau-Roßlau 2011;

https://www.umweltbundesamt.de/publikationen/expositionsbetrachtung-beurteilung-des-transfers


Special management of contaminated sites

Contaminated sites are in general suited for a special management which is administrated and fi-nanced by separate sources. This management is a long-term task and needs decades for the identification, the risk analysis, the planning of remediation and decontamination and the final reali-sation and financing of all steps. Typical contaminated sites that need the special management are

former dumpsites and illegal deposits of wastes that do not fulfil the state of the art or another acceptable standard which is defined by the competent authority during the accession process,

industrial sites that were used as production plant, power plant including supply devices or waste management facility and which are out of operation,

former mining areas.

It is recommended to create a special administrative unit to manage the decontamination and the remediation of these contaminated sites. Sites which are contaminated with POPs should be sub-ject to this special management, too, (e.g. with POPs pesticides contaminated stockpiles and tem-porary storage facilities, areas with contaminated construction and demolition material, flooded ar-eas that are proven to be contaminated with POPs…)

Clarification of disposal options for POPs-containing wastes

The main governmental aim is to export POPs-containing wastes to suited waste treatment plants abroad, especially in Europe. The reason is the absence of suited treatment plants in Serbia itself. The required technologies for the final treatment of POPs-containing wastes comprise usually thermal treatment operations in waste incineration plants or in suited co-incineration plants like power stations and cement kilns. This option does not distinguish between certain technologies, e.g. the incineration in rotary kilns or within grate incineration. So the technical status and the granted permit decides whether the incineration of POPs-containing wastes is allowed.

It shall be taken into account that in Serbia three cement kilns are operated and two of them are al-lowed to co-incinerate wastes, too. The incineration in cement kilns guarantees high processing temperatures and long processing times, and represents the state of the art for the hazardous waste disposal. But POPs-containing wastes are currently not part of the relevant licences of these plants in order to limit the input of chlorine into the burning process because of the corrosive be-haviour. Nevertheless, it should be checked together with the operators of the plants if the operated cement kilns can be empowered for the input of small amounts of POPs-containing wastes with a defined POPs content and provided that a dispensed input in the cement kilns is guaranteed. If it is possible and the operators are willing to empower the cement kilns for the disposal of POPs wastes, an annual disposal plan shall be established.

In the same way, it shall be checked whether other thermal treatment facilities could be suited for the disposal of certain POPs-containing wastes. Other possible thermal treatment options are in-cineration processes in power plants as well as metallurgical operations in plants which meet the limit values on PCDD/PCDF from Incineration Directive 2000/76/EC. Especially for the disposal of smaller amounts of POPs-containing wastes and wastes with a low POPs concentration (e.g. packaging material, light fraction from shredding processes) it could be a suited solution.


Mineral wastes from thermal processes, from construction and demolition and from thermal waste treatment are characterised as potentially POP-containing wastes, too. But these kinds of wastes are not suited to be treated in thermal processes. According to the EG-Regulation 850/2004, these kinds of wastes are subject to a permanent storage in certain plants instead of destruction of POPs content. Legally possible storage options are

deep underground rocks,

salt mines, this includes the stowage of former salt mines as well as underground landfills

landfills for hazardous wastes, provided that the POPs-containing wastes can be disposed as solidified or stabilised waste.

It shall be checked whether landfills or certain areas of landfills can be activated for the disposal of these kinds of waste.

The recovery of POPs containing wastes shall be avoided if the concentration is above the lowest limit values determined in Annex IV of the Regulation 850/2004. Especially wastes from the pre-treatment (dismantling, sorting, shredding…) of complex wastes aim on the recovery of valuable substances or fractions from wastes. This is according to the principle of the priority of waste recy-cling, but in connection with POPs the problem of distribution of pollutants within the product cycle can be faced an shall be avoided. Especially in case of pre-treatment activities for fractions with expected POPs content (WEEE, end-of-life vehicles) it shall be guaranteed that a distribution in the cycle management is prevented.

In the same way, it shall be guaranteed that fractions of wastes that theoretically can contain POPs but actually do not contain any POPs are used for a further recycling. This is especially applicable on polystyrene insulation materials that can but do not have to contain HBCD. A correct distinction of POPs and non-POPs containing fractions shall be guaranteed before further disposal measures.

Marked based instruments

As mentioned in chapter 10.1.2, a control mechanism on the marked label could help to detect products that contain POPs. If there exist regulative legal instruments for the placing of products on the market, it makes only sense if these conditions can be supervised. Such a control is needed and effective especially in cases when products are imported from countries which did not ban the use of POPs in formulation or production of goods. A control system would not only help to detect certain substances in products but also to support the enforcement of European and Serbian Legis-lation of restrictions (limit values) and bans concerning POPs. Illegal placement on the marked could be detected and be punished.

Relevant goods for marked based control systems concerning POPs are especially

electric and electronic equipment and parts of them,

textiles, clothes, and goods with textile surfaces,

toys made from plastic parts or textiles

oils and lubricants made from refinery products gained from waste oil recovery

paints, lacquers and coatings, glues

heat insulation systems

…

The installation of such a control mechanism needs to be discussed within the Government and with the stakeholders because it represents an additional administrative instrument which causes and generates additional administrative costs (staff, sampling and analysis, general administration).


Information based instruments

The extent of the presence of new POPs is not sufficiently understood; inventories are required to fill this information gap. In addition, awareness raising should be intensified within the producers, treatment plants and especially the waste disposal plants regarding new POPs. The main aim shall be to inform about the exposure to POPs and the potential health and environmental dangers. There is a need to be able to identify new POPs in articles and products that are imported into countries. The following strategies and measures should be considered:

Develop the capacity of customs authorities to identify POPs and articles containing POPs, through increasing technical capacity and human resources in customs offices and through col-laboration at the regional level,

Promote information sharing at the regional level and information transfer to countries in the re-gion, regarding techniques for identifying new POPs and their presence in articles,

Increase the availability of information and awareness raising about the presence of POPs in ar-ticles and exposure routes to these substances throughout the life‐cycle of such articles,

Inform in general about the health risks resulting from POPs in products (orderly use) and in wastes (disorderly use with additional environmental risks).

Strengthen regulations to increase the protection of workers of the waste disposal and recycling in-dustry, for example PCB-decontamination, WEEE disposal, shredding measures and to prevent re-leases of POPs to the environment from that industry.

Voluntary instruments and voluntary agreements

The responsibility for managing new POPs and articles containing new POPs throughout their life cycle should be shared by manufacturers. The following strategies and measures should be con-sidered:

a) Companies that produce new POPs and that manufacture articles containing new POPs should facilitate the identification of such articles and the way in which these should be disposed of. Regu-lations should be introduced to require the labelling of articles for their POPs content and for their environmentally sound disposal.

b) Producers of new POPs should provide clear information about these chemicals to allow aware-ness raising and to facilitate their environmentally sound disposal.

c) Mechanisms should be developed for returning articles containing POPs to the manufacturers for their disposal.

d) Partnerships with and voluntary participation by industry should be encouraged, for example, by including manufacturers in the process of developing regulations.

e) Countries should take advantage of existing regional and international platforms, such as the Partnership for Action on Computing Equipment (PACE) of the Basel Convention, for cooperating with industry towards the life‐cycle management of articles containing POPs.


10.2 Assignment of responsibilities for implementation of measures

In all tables of waste stream related action plans the responsibilities for implementation have been assigned within the preceeding chapters. 10.3 Assessment of useful effects and sustainability of application of

economic and other instruments in waste management, with undisturbed functioning of internal market

To assess effects and the usefulness of defined measures and their market influence several spe-cific aspects like protection of environment and human health, public interests, technical and eco-nomical feasibility, national framework and strategies (e.g. defined recycling targets) are of rele-vance. In the following some aspects are shortly discussed:

Taxation on landfilling of hazardous waste:

In Serbia, taxation on waste to be landfilled is still low compared to other European Countries. Up to now, dumping with very low costs seems to be the usual case. If the option to recycle waste is much more expensive compared to landfilling, recycling activities will remain poor. Taxation is an important element to reduce the amounts of recyclable wastes ending at landfills.

There is a public interest that specific wastes with high potential to harm people and the environ-ment are treated in an environmental sound manner. If landfilling of those hazardous wastes is the most appropriate option (e.g. for asbestos containing waste or tar containing bituminous waste), taxation seems to be justified in order to protect the public interests.

But, in order to be economic viable, the landfill tax shall be introduced in a period of time (3 years for example) in order to let the industry to organize alternative solutions for waste treatment. If not, the tax will increase the costs of waste management.

Call up for treatment capacities and treatment activities in the private sector:

Only a combination of measures will influence the private sector in that way that the operation of treatment facilities is economically feasible. One of the most important aspects is the existence of legal certainty. Measures to set up the legal framework seem to be of high importance and should be implemented in short timeframes. Principles of equal opportunities and prosecution (e.g. in terms of punishment on illegal activities or illegal dumping) are basic requirements for functioning of a market and should be strengthened.

Extended Producer Responsibility (EPR)

Extended Producer Responsibiliy is a potential tool for increasing recycling in areas where market factors do not otherwise financially incentivise collection and recycling. In the European Union, ex-tended producer responsibility is mandatory within the context of the WEEE, Batteries, and ELV Di-rectives. In Some Member States, EPR-Systems have been introduced covering a broader range of waste streams. (European Commission – DG Environment 2014)

According to the report of the project “Development of Guidance on Extended Producer Responsi-bility (EPR)” commissioned by the EC, great discrepancies can be observed in performance indi-cators related to the EPR-models at the EU-28 level. While no single EPR-model emerges as the best performing and the most cost-effective, it can be concluded that the best performing schemes are, in most cases, not the most expensive. (European Commission – DG Environment 2014)


11 CRITERIA FOR SITE IDENTIFICATION AND NECESSARY CAPACITIES OF NEW ESTABLISHMENTS FOR RECOVERY AND/OR DISPOSAL OF WASTE

11.1 Search Criteria and search procedure for hazardous waste landfill sites

Corresponding to the “Multi-Barrier Concept” (Fig.1) which is the State of Art in landfill technology, each security system of disposals consists of three independent elements: the adequate pretreatment of waste in order to diminish or destroy it's inherent environmental

risk, the all-around isolation by geotechnical barrier systems, preferably by natural, mineral soils

and the selection of a geologically suitable site (Fig. 2) of low permeability and of low water re-

sources vulnerability. The level of necessary safety measures depends on the environmental risk of waste to be land-filled. Therefore, hazardous waste demands the highest security level in terms of pre-treatment, quality of site, landfill techniques applied, supervision, and monitoring. Due to the long term environmental risk of landfills in general and of hazardous landfills in this spe-cial case, landfills need a geological barrier in order to activate - in the case of break of technical confinement - the sealing properties and the retention capacity of the underground (compare Fig.2). The requirements defined for this geological barrier in term of quantitative properties of the geolog-ical underground must also take into consideration the necessity of accessibility and proximity of the sites relative to the waste generating locations. Extreme geological barrier requirements risk to aggravate the site searching procedure, the transport distances and the acceptance by waste gen-erating industry.

Fig.1: Main components of the Multi-Barrier Concept


11.1.1 Significance of geological barrier

The quality of the geological barrier against groundwater contamination has a certain priority be-tween the site searching criteria, the site searching procedure and within the evaluation of site al-ternatives. It should be clearly identified within the hazardous waste management plan that in the course of the evaluation of site alternatives, the criteria of geological barrier quality and of groundwater vul-nerability enjoy a major importance, and from all these criteria, the highest possible degree of suit-ability should be aspired to this. Three main groups of criteria should be distinguished in site searching regulation: 1. Geological criteria for the sealing and retention capacity of the immediate natural underground

of the landfill (e.g. thickness, permeability and clay content of the geological strata) 2. Criteria describing the water resources vulnerability (e.g. distance from water table and from

drinking water capture areas), and 3. Planning restrictions concerning the domain of mining, settlement, traffic, natural reserve, rec-

reation and other infrastructure measures.

In Operation after Operation (in case of incident) STABILITY IMPERMEABILITY

high retentionADSORPTIVITY capacity

- low compressibility - high erosion resistance - high density - high plasticity - low solubility

- homogenous - low permeability - thick - low dispersivity and diffu-sivity - large distribution in space - small hydraulic charge

rich of ... - clay fraction - adsorptive material - swelling minerals - low degree of diagen-esis - non-folded - without faults and fractures

Fig. 2: Geotechnical criteria for the quality of the geological barrier during a site search procedure for hazardous waste disposals 11.1.2 Stepwise approach to suitable sites

These criteria have to be structured and ordinated, corresponding to the strictness of criteria in: Exclusion criteria and minimum requirements, whose fulfillment is compulsory, otherwise the site

is excluded from further search procedure, Evaluative criteria with graded importance within searching procedure, and Supplementary criteria, whose fulfillment is a useful addition for the decision making process.


Hydrology and groundwater protection

Nature reserve Settlement, infra-structure

Mining Hydrogeology

- valleys, rivers and lakes - important groundwater reserves - reserved areas for water management (important water bod-ies) -drinking water pro-tection zones - thermal and other medical sources - inundation zones

- nature reserve - natural forests

- large constructionprojects - settlements and its surroundings - industrial zones - areas of public inter-est - recreation areas - airports - cure areas and its surroundings

- areas under mining influence - future mining areas - raw material re-serve

-geological for-mations with in-adequately high permeability

k > 1x10-7 m/s; (large scale)

Fig. 3: Large scale exclusion criteria within a site searching procedure for hazardous waste dis-posals 11.1.2.1 Exclusion criteria and minimum requirements

Exclusion criteria are important public concerns which have been fixed and have entered into force by other regulations. They describe spaces that are excluded from further site searching process.

Minimum requirements are criteria, which must be fulfilled to consider a certain space in fur-ther searching procedure.

Like mentioned before, geological criteria are primordial for long term security of the landfill. There-fore important minimum requirements are: Minimum distance of groundwater level to the landfill basis is 1 m Permeability of the geological strata underneath the landfill should be very low (reference

depth 5 m). Inclination of the landfill bottom should be less than 1:7 and Geotechnical stability of the geological strata underneath the landfill should be sufficient (ref-

erence depth 10 m). Further important exclusion criteria are: Position within karst aquifers and fissured rocks Position within drinking water protection zones Position within inundation zones Position within settlements (see distance criteria) Position within natural reserve Position within areas influenced by mining activities (cavities, raw material reserve) Position within officially fixed recreation areas

These criteria are binding conditions of the HWMP. During the first steps of investigation the exclu-sion criteria and minimum requirements criteria are considered to by superposing maps with these negative areas and determining the residual searching areas.


11.1.2.2 Evaluative criteria

The evaluative criteria are applied to the residual areas and enter into competition with other plan-ning purposes. The criteria are put into a system of graded assessment (++/+/ 0/ -/--) and – by su-perposing these criteria - areas of graded aptitude are determined. This is a highly iterative and evaluative process. Such evaluative criteria of importance are: Minimum distance to settlements (500 – 700 m) Position within or in proximity of important water bodies Proximity to important biotops, archeological monuments and natural testimonies Proximity to areas of special public interest (military areas, airports etc.) Proximity of and accessibility to important traffic infrastructure (railway, waterway, highway)

11.1.2.3 Additional site selection criteria

Those are criteria which should also enter into the site selection and evaluation process because they describe circumstances marking the social, technical or economic feasibility of the resulting site. Such criteria can be: Favorable conditions for water and electricity supplement Favorable conditions for use of waste energy of the plant (in case of incineration) Favorable conditions concerning availability of the ground Favorable conditions concerning geotechnical suitability of the building ground Proximity to other waste and wastewater activities (e.g. waste water treatment) Favorable conditions concerning main direction of wind Safe and nearby disposal of residues and effluents Favorable conditions concerning potential work places

11.1.3 Systematics of searching procedure

The site examination is generally subdivided into two phases: the preliminary location prospecting, and the main location investigation.

The preliminary location prospecting represents a comparative study: On the basis of the results of large scale exclusion criteria, small scale exclusion criteria and evaluative criteria are applied to the residual searching areas. Step-by-step evaluation leads to three to five selected promising locations that might be suitable for main location investigations. For these locations, confirmed by state agencies, the entities in charge take decision on main loca-tion investigations. The main location investigation is - in essential - a hydrogeological suitability investigation of elected locations. It leads to a comparative environmental impact assessment study and prepares scientifically the decision-making. The final and comparative evaluation of the studied locations leads to a list of preference that is presented to the entities in charge (National or Regional Planning Board or the Waste Management Commission) for decision-making.


Step of process Concerned area Method

Preliminary Determination of search areas

Regional or national territory Superposition of largescale exclusion areas

Determination of promising areas

Several search areas Superposition of small scale exclusion areas

Preliminary Investigation: Focusing and preliminary se-lection of smaller areas

Many promising smaller areas

Superposition of important evaluation criteria, iterative pro-cess

Main Investigation, 1. step Comparative Environmental Impact Assessment (EIA)

Few very promising locations

Investigations in place; compar-ison and final evaluation of fea-sible locations; decision for one or two sites of landfill

Main Investigation, 2. step Object planning and corre-sponding EIA

One landfill site with surround-ings

Calculations and approxima-tions of emissions and its im-pact; planning of construction operation and supervision of the disposal

Fig 4.: The site searching procedure for a hazardous waste landfill within a defined regional unit

11.1.4 Site selection

As a result of the searching procedure, one or two alternative sites are safeguarded by legally pre-scribed administrative planning processes: The introduction of the selected site(s) in the Regional Planning documents helps to safeguard this space for waste management purposes for a long time and independent of the duration and result of the political struggle which is common within Region-al Planning processes with its competitive interests. The Regional Planning Act is set up by the Regional Planning Board.

11.2 Search criteria for other hazardous waste recovery and treatment

plants

Search criteria for other hazardous waste recovery and treatment facilities than landfills, like chem-ical-physical treatment and incineration plants are subdivided in Exclusion criteria plus minimum requirements, whose fulfillment is compulsory, otherwise the

site is excluded from further search procedure and Additional site selection criteria, whose fulfillment is a useful addition for the decision making

process. 11.2.1 Exclusion criteria and minimum requirements

Exclusion criteria are other important public concerns which have been fixed by other regula-tions. They describe spaces that are excluded from further site searching process.

Minimum requirements are criteria, which must be fulfilled to consider a certain space in fur-ther searching procedure.

These criteria are binding conditions of the HWMP.


11.2.2 Additional site selection criteria

Criteria which should have a high significance for the selection of a site because they describe cir-cumstances at a site which need protection (Nature reserve, water protection, recreation areas etc.) or which are of technical or economic importance (distance to railway, to highways etc)

One of the additional criteria or even of the minimum requirements is the position of selected sites within official commercial or industrial zones which might facilitate the application of other exclusion criteria which are allready considered in the process of admission of industrial and commercial zones. Only in the case that suitable sites are not to be found within these zones, search procedure should be enlarged to areas outside. Other criteria of importance are: Minimum distance to settlements (500 – 700 m) Safe disposal of residues Level of resulting emissions under legally prescribed limits

Further criteria can be: Favorable conditions for water and electricity supplement Favorable conditions for use of waste energy of the plant Favorable conditions concerning availability of the ground Favorable conditions concerning technical suitability of the building ground Favorable distance to railway, waterway and/or highway Proximity to other waste and wastewater activities (e.g. waste water treatment) Favorable conditions concerning main direction of wind Favorable conditions concerning potential work places


12 REFERENCES

COWI & EURO HEALTH GROUP (2013): Technical Assistance for the Treatment of Healthcare Waste in Ser-

bia. National Plan for the Management of Waste Originating from Healthcare Facilities and Phar-

maceutical Waste. Planning Report Contract N°: 08SER01/31/12/001. February 2013.

EUROPEAN COMMISSION – DG ENVIRONMENT (2014): Development of Guidance on extended Producer Re-

sponsibility.

MAEP (2012): Draft Serbian Waste Management Plan for Asbestos-containing waste: Draft Version 5.0,

Ministry of Agriculture and Environmental Protection.

MAEP (2015): Environmental Protection Report 2015

MAEP (2010): The national waste management strategy for the period of 2010-2019 ("Official Gazette of

RS” no. 29/2010): Ministry of Agriculture and Environmental Protection.

MAEP & UMWELTBUNDESAMT (2016): Serbian Waste Management Plan for Hazardous Construction and

Demolition Waste. Draft dated with 31st of July 2016. Twinning Project SR 13 IB EN 02.

MAEP & UMWELTBUNDESAMT (2016): Draft Serbian Waste Management Plan for Oil Wastes. 31 August

2012 (Update 2016, drafted with 25th of November 2016). Twinning Project SR 13 IB EN 02

MAEP & UMWELTBUNDESAMT (2016): Draft Serbian Waste Management Plan for End-of-life Vehicles. Twin-

ning Project SR 13 IB EN 02

SEPA (2015a): Trends with hazardous waste generation and treatment. Presentation during first workshop

SEPA (2015): Waste data for 2014 (Extract of data prepared for this project)

STATISTICAL OFFICE (2015-1): Waste Statistics in the Republic of Serbia 2010-2013 in accordance with the

Regulation on Waste Statistics EC No. 2150/2002, Statistical Office of the Republic of Serbia.

STATISTICAL OFFICE (2015-2): STATISTICAL RELEASE ZS60 NUMBER 199 • YEAR LXV, 30/07/2015

ENVIRONMENTAL STATISTICS.

ANNEX Title


13 ANNEX

13.1 Part A – Information on the consultation process

13.1.1 Members of the planning team of this WMP

On October 8, 2015, MAEP adopted a final Decision on the establishment of a working group dedicated to the development of the integrated hazardous waste management plan.

The working group consists of 31 members:

Institution

Ministry of Agriculture and Environmental Protection, Waste Department

Ministry of Agriculture and Environmental Protection, Sector of Inspection for Environmental Protection, republic inspector

Ministry of Agriculture and Environmental Protection, Sector of Inspection for Environmental Protection, Department for Project Management

Ministry of Agriculture and Environmental Protection, Department Environmental Impact As-sessment

Ministry of Agriculture and Environmental Protection, Group for Strategic Environmental Impact Assessment

Ministry of Agriculture and Environmental Protection, Department for IPPC

Ministry of Agriculture and Environmental Protection, Section for Huge Chemical Accidents

Chamber of Commerce Serbia

Chamber of Commerce Belgrade

Serbian Environmental Protection Agency

Ministry of Health, Group for Public Health

Ministry of Construction, Traffic and Infrastructure, Department for international transport

Ministry of Finance, Tax Office, Sector for Material Resources, Regional Department Belgrade

Province Secretariat for Urban Planning, Construction and Environmental Protection

Faculty of Technology and Metallurgy Belgrade

Ministry of Interior – Sector for Emergency Situations

Ministry of Interior – Police Directorate

Ministry of Interior – Directorate for Traffic Police

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