Review of the Montenegrin Draft Bylaw for Implementing EPR and for Establishing EPR for Tires

Beneficiary: The Ministry of Ecology, Sustainable Development and Development of the North of Montenegro

 

Making use of our GAP for EPR Helpdesk, the Ministry of Ecology, Sustainable Development and Development of the North of Montenegro has reached out for support. Together with our experts, the GAP for EPR reviewed a planned Bylaw for implementing an Extended Producer Responsibility System.

The Montenegrin Waste Management Law was adopted in 2024. It states that an Extended Producer Responsibility system ought to be established as soon as the bylaws are adopted. Accordingly, the Ministry of Ecology, Sustainable Development and Development of the North of Montenegro has developed a general EPR Bylaw, as well as a specific Bylaw for establishing EPR for tires, the first EPR scheme to be introduced in Montenegro.

GAP for EPR Experts evaluate the Montenegrin EPR Bylaw

Giving concrete recommendations, the GAP for EPR and its experts reviewed the legislative package especially for the general and the tires Bylaws that are currently under development. The goal of the review was to identify regulatory progress, structural coherence, and legal alignment with European Union Directive 2018/851/EU.

The Waste Management Law was found to generally provide a strong basis for EPR legal framework and aligning national waste policy with the principles of the EU Circular Economy and the requirements set out in Directive 2018/851/EU.

Some of the suggestions included in the feedback stated that the draft requires..

  • Increasing clarity on achieving national coverage by e.g., defining minimum service coverage thresholds, establishing rules for service availability in low-density or remote regions, and introducing coordination tools (e.g. clearinghouse or shared infrastructure agreements). This will allocate service responsibilities fairly among multiple systems;
  • More clarity on the institutional and organisational structure, e.g., how will multiple organized systems coexist, compete, or be regulated to avoid service duplication or fragmentation?
  • Producers’ obligations: more clarity regarding timelines for registering and on procedures;
  • Inclusion of (recycling) targets in the Tire waste Bylaw.

The Ministry of Ecology, Sustainable Development and Development of the North of Montenegro took note of the suggestions and will now develop the legislative framework further.

 

The EPR Helpdesk

The EPR Helpdesk offers customized technical assistance upon request for the design and implementation of EPR to governments and producer responsibility organizations (PROs), as well as other relevant stakeholders such as informal sector organisations. With its diverse pool of EPR experts, the Helpdesk supports short-term requests as well as long-term EPR pilots. Together with WWF and the PREVENT Waste Alliance, UNEP has taken a leading role in its formulation and execution.

 

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