Waste management report

The deadline for submitting the Annual Waste Report is 31 March 2021

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The Law on Waste Management stipulates the obligation of producers, waste owners and other waste holders to submit and keep daily records of waste and submit a regular annual report to the Environmental Protection Agency (hereinafter “Agency“), in accordance with the law and bylaws, until 31 March of the current year for the previous year.

In addition, it is prescribed that both producers and importers of products, which after use become special waste streams, are obliged to submit and keep daily records on the quantity and type of produced and imported products, i.e. submit a regular annual report to the Agency or the National Pollution Source Register.

In this regard, the Law on Waste Management has defined a “Waste Producer” as any person whose activity generates waste or any person whose activity results in a change in the composition or nature of waste prior to treatment, mixing or other procedures.

Special waste streams represent the movement of waste (spent batteries and accumulators, waste oil, waste tires, waste electrical and electronic products, waste vehicles and other waste) from the place of generation, through collection, transport and treatment, to landfill.

The annual waste report is filled in and submitted electronically, through an application that is available on the Agency’s website. Based on the Rulebook on the form of daily records and annual report on waste with instructions for its completion, all waste producers and all waste management entities, as well as those who put packaging and products that after use become special waste streams are obliged to submit annual reports.

For special waste streams, importers are obliged to submit an annual report on special waste streams to the National Register of Pollution Sources. In addition to the annual report, the Decree on products that after use become special waste streams prescribes the obligation to keep daily records of products that are placed on the market of the Republic of Serbia, and which after use become special waste streams. Companies can submit daily records in paper or electronic form.

In addition, companies and entrepreneurs who produce or import products that after use become special waste streams, are obliged to, on the basis of daily records and annual reports on special waste streams, calculate the tax, ie. fees for special waste streams, as well as to make the payment of this fee.

For non-submission of annual reports in accordance with the law and bylaws, misdemeanor liability of commercial entities is envisaged such as:

• A fine of 500,000 to 1,000,000 dinars for a company, provided that the fine may be imposed in proportion to the amount of damage or unfulfilled obligation, the value of the goods or other items that are the subject of the violation, up to twenty times the amount;

• A fine in the amount of 25,000 to 50,000 dinars for the responsible person in the company;

• As well as a fine of 250,000 to 500,000 dinars or imprisonment for up to 30 days for entrepreneurs.

This article is for informational purposes only and does not constitute legal advice. If you need additional information related to this topic, feel free to contact us by email office@ncrlawyers.com or by phone +381677049551.