Paths and the Directions of the Waste Trading inthe Countries of the Euro - Mediterranean Region:Serbia and Montenegro (With an Emphasis on the

Latter)

Daša Janja Banovec

Republic of Montenegro has inadequate waste management. They are

typically disposing solid, industrial and municipal waste of in

landfills or illegal dumps across the country. Many times they are

incinerating this waste in an inappropriate way. The absence of

regulated landfills and recycling facilities contribute to landscape

degradation. Among the key challenges facing Montenegro’s urban

environment are illegal waste dumping and a lack of wastewater

treatment facilities and aging infrastructure (Vasiljević, n.d.).

Aluminium Factory Podgorica, Niksic Steel Factory and Plevlja

Thermal Power Plant are serious pollutants, responsible for

negative environmental effects and contamination. There are also

problems with industrial liquid wastes being discharged to rivers.

(European Environment Agency [EEA], 2010).

The area of waste trading is still a relatively unexplored and

treated poorly by the experts. Also, available data do not always

show the real situation. For many years, Montenegro has problems

with illegal waste disposal. Well, in recent years, experts and

international organizations, including the state, are dealing with

the problem. Some progress on waste management can be seen in

adoption of implemented legislation related to permits for import

and export of waste and treatment of certain waste streams (European

Commission [EC], 2011). »As regards infrastructure, the first

recycling centre has begun operating in Podgorica. Most waste,

however, is still disposed of in open sites or multiple unauthorised

dumps« (EC, 2011 : 68).

International cooperation in waste treatment, especially in

hazardous waste treatment is a common practice in Europe and

elsewhere. Some countries may produce only small amounts of

hazardous waste, which needs for example an extremely high

temperature incinerator for final disposal. If a country does not

have treatment facilities fulfilling European standards on hazardous

waste treatment, waste can be exported to licensed facilities abroad

in accordance with national and international legislation (Republic

of Serbia, Ministri of Environmrnt and Spatial Planning [RS, MESP],

2011). »In these cases, the option of transporting hazardous waste

to treatment plants located in neighbouring countries is chosen, in

accordance with international agreements concerning the transport of

hazardous goods. The Basel Convention on Transboundary Movement of

Hazardous Wastes and their Disposal sets the rules for exporting

hazardous waste« (RS, MESP, 2011 : 9). Serbia and Montenegro are

signatories of the Basel Convention from 1999. For both countries,

an important element for hazardous waste management is the export of

such wastes in accordance with the Basel Convention and the national

legislation. Basel Convention gives the right for each party of the

convention to prohibit the importation of hazardous waste. Some

European countries, like Serbia and Montenegro, have banned the

import of hazardous waste. Regulation in European Union, which

fulfils Basel Convention requirements is the Regulation of shipments

of waste (1013/2006). In some aspects, it is stricter than Basel

Convention (RS, MESP, 2011), with tight requirements regarding

hazardous waste. Also, requirements are tighter for disposal than

for recycling (European Topic Centre on Resource and Waste

Management [ETC/RWM], 2008).

1 Review of waste trading literature

The literature in the form of professional articles and studies

about Montenegro's waste trading practically does not exist. Until

recently, legislation relating to the waste management and waste

trading was also acutely sparse. Ecologists, international

organizations and the European Union began putting pressure on

Montenegro to resolve those issues. Consequently, in recent years

the state and its authorities are seeking to establish an effective

legislative and regulatory framework to prevent various forms of

environmental crime, including handling and waste trading.

Montenegro has put more emphasis on legislation which slowly follows

European guidelines and the guidelines of developed countries. In

this section, we are going to define waste and present existing

legislation in the field of waste trading in Montenegro and its

horizontal legislation.

Constitution of Montenegro (Official Gazette of Montenegro, no.

1/07) in article 1 defines Montenegro as a »civic, democratic and

ecological state, based on the respect of social justice and rule of

law«. In 2008, Montenegro adopted a new Law on Environment which

establishes legal and strategic mechanisms and institutional

framework for the environment in Montenegro. This law, among other,

establishes the responsibilities for the damage caused to the

environment, the process of reporting on the condition of the

environment in accordance with the standard methodology of the

European Agency for Environment through the obligation of

establishing the national directory of environment related

information system in accordance with the European standards

(Kostić-Mandić, 2011). The Law on Environment (Official Gazette of

Montenegro, no. 48/08) represents significant environmental

protection framework act which serves as a base for other

environmental Legislations. It also prescribes the polluter and user

pay principles. In 2011, Montenegro adopted the Law on Waste

Management, which represent the normative framework in the area of

waste management. The Law on Waste Management (Official Gazette of

Montenegro, no. 64/11) describe the prevention or reduce of the

amount of the waste, reuse of waste collection, transport,

processing and disposal facilities, monitoring of these procedures

and maintenance of the landfill. The law provide principles of the

waste management including the polluters pay principle and describe

the various type of waste. The law also points that the type of

waste shall be determined based on the hazardous properties and

their characteristics. The law specify the responsibility to the

waste producer and require manufactures to limit the amount of

hazardous waste. Important document in the field of waste management

in Montenegro is Waste Management Plan (Official Gazette of

Montenegro, no. 16/08) for the period 2008-2012, which describes the

handling and management of waste in Montenegro. Although the plan is

focusing mainly on household waste, it also includes a reference to

hazardous and industrial waste. Waste Management Plan (WMP) defines

hazardous and industrial waste and emphasize the importance of

proper handling of waste from industry subjects like the Aluminium

Plant in Podgorica, Niksic Steelwork and Pljevlja Thermal Power

Plant. WMP also presents current handling of hazardous and

industrial waste concluding that country has no storage or disposal

of hazardous waste declared as a constant disposal that meets the

basic safety criteria. That would solve the problem of disposal of

industrial hazardous waste in Montenegro (COWI, 2012).

In various national Legislations waste are differently defined,

because each country is drawing these definitions based on country's

experience and economic needs. Montenegro defines waste as a

material or object which the holder discarded intends or is required

to discard (Law on Waste Management [LWM], 2011). The Law on Waste

Management (LWM) defines non-hazardous waste as waste, whose

components and characteristics do not have any characteristics of

hazardous waste. This Law also indicates a hazardous waste as waste

containing elements or compounds with one or more harmful

characteristics. These properties are explosiveness, reactivity,

flammability, irritability, harmfulness, toxicity, infectivity,

carcinogenicity, corrosiveness, mutagenicity, teratogenicity,

ecotoxicity, etching property and property release toxic gases

chemical or biological reaction and sensitivity/irritability, as

well as the waste from which, after a delay, another substance that

have some of the hazardous properties may occur (LWM, 2011).

Transboundary movement of waste is defined as waste exports and

imports and transit of foreign waste through national territory

(LWM, 2011). In Montenegro, import of hazardous waste is prohibited,

while the export and transit of hazardous waste is subject to

licensing. Permit is also required for import and transit of non-

hazardous waste. The export of non-hazardous waste requires only

official record in the register of non-hazardous waste exporters

(LWM, 2011).

In Montenegro, the Law on Foreign Trade and the Decree on

Implementation of the Law on Foreign Trade prescribe conditions and

procedure for issuance of a license. Issuance of licenses for

export, import and transit of goods within the licensing regime is

determined by the decision based on Control List for Export, Import

and Transit of Goods (http://www.ceftatradeportal.com).

Environmental Protection Agency (EPA) is responsible for issuance of

licenses for import, export and transit of waste, radioactive

substances and sources of ionizing radiation. EPA is issuing permits

for import, transit and export of waste using the Law on Waste

Management (Official Gazette of Montenegro, no. 64/11), the Law on

ratification of the Basel Convention on transboundary movements of

hazardous wastes and their disposal (Official Gazette FRY,

International Contracts, no. 2/99) and provisions of the Rules on

the content of the documents, which shall be annexed to the request

for a license for import, export and transit of waste and the waste

classification list (Official Gazette of Montenegro, no. 71/10). In

accordance with the Basel Convention, Montenegro has formed a

Checklist, which defines waste prohibited for import and waste for

which permit is required for the export, import and transit.

The request for a license for import and transit of non-hazardous as

well for export and transit of hazardous waste must be accompanied

by a report on the properties of the waste, document on the approval

of all countries through which the waste is transferred, the signed

contract between importers and exporters and other evidence in

accordance with the law. The requestor for a permit for the

transboundary movement of waste (hazardous and non-hazardous) must

provide adequate financial guarantee or insurance which is in

accordance with the legislation of the country of import or transit

in the amount needed for waste management costs and remediation

costs in case of damage. Import and export of non-hazardous waste

request fee payment in the amount of 5 €. That money goes to

Montenegrin budget. Export and transit of hazardous waste request

fee payment in the amount of 10 € per tonne of hazardous waste. In

this case, the recipient of the fee is EPA (http://www.epa.org.me/).

According to government officials, it is not difficult to obtain

permits and permit should be issued in less than 30 days.

»The Law on Foreign Trade prescribe that the goods, the trade of

which has been banned in Montenegro can not be imported. The

Decision on the Control List for Export, Import and Transit of Goods

contains the list of dangerous waste (Official Gazette of

Montenegro, no. 10/11), the import of which has been prohibited in

Montenegro. Also, trade in nuclear materials and radioactive waste

has also been prohibited« (http://www.ceftatradeportal.com).

Given the fact that Montenegro seeks to become a member of the

European Union, it is necessary to mention the directives and

regulations related to transboundary movement of waste. Especially

important are Directive on Hazardous Waste and Regulation on

shipment of waste. Directive on Hazardous Waste (91/698/EEC) aim is

to ensure the disposal, exploitation and proper storage of hazardous

waste monitoring in the best possible way. According to this

Directive, the Member State must make sure that the hazardous waste

is registered, identified and not mixed with other harmless or

hazardous waste (Madix, 2008). Waste Shipment Regulation (1013/206)

regulates the supervision and control of waste import and export in

the European Community. »One of the main aims of these regulations

is to prevent illegal shipments of harmful waste to countries that

do not have the technology to cope with these wastes. For example

illegal export of toxic wastes« (European Union Network for the

Implementation and Enforcement of Environmental Law, 2006 : 56).

Given the fact that until 2006, Montenegro and Serbia were together

in the State Union of Serbia and Montenegro, we will briefly

introduce legislation of the Republic of Serbia in the field of

waste trade. First, we must emphasize that Serbia and Montenegro

adopted the Law on Ratification of the Basel Convention during the

State Union of Serbia and Montenegro, which now applies in Serbia as

well in Montenegro. Serbia has (adopted in 2004) Law on

Environmental Protection which presents legal framework for

environmental protection and regulates import, export and transit of

waste. They also have Waste Management Law which regulates the

management of waste substances that can be used as secondary

resources, conditions of their acquisition, processing and

maintenance and the Law on Transport of Hazardous Substances. Serbia

has also adopted a variety of regulations:

Regulations for Documents Submitted with Request for Import, Export

and Transit of Wastes which contains regulations related to the

contents of documentation required for the issue of cross-border

waste traffic permit;

Regulations on Management of Substances with Hazardous Properties

prescribe handling of substances with hazardous characteristics,

particularly storage, list of waste that must be controlled in

accordance with Basel Convention and recording on these substances;

Regulations on Conditions and Methods for Classification, Packing

and Care of Secondary Raw Materials which contains waste catalogue

and list of waste in line with European documents, with prescribed

content of Document on waste classification and Document on waste

management;

Regulations on Criteria for Determining Location and Disposition of

waste, processing facilities, temporary storage or final disposal of

waste. Serbia also prohibits the import of hazardous wastes from

abroad in order to dispose it permanently or temporarily on the

territory of Serbia - according to the Law on Environmental

Protection and Law on Transport of Hazardous Substances. Serbian

Criminal Code contains a special chapter named Criminal Acts against

the Environment. It renders import of dangerous substances into the

Republic of Serbia, processing, disposal, storage of hazardous

wastes without a permit as criminal act (Workshop on Illegal

Traffic, 2006).

2 Review of waste trading studies

We have not found any facts, documents, studies or detected cases of

illegal waste trading in Montenegro. Even available data on legal

waste trading by Montenegro with other countries are sparse. As

well, availability of waste trading studies and data is limited.

Waste volume in the Republic of Montenegro is hard to estimate. The

main reason is a lack of waste qualitative and quantitative

analysis.

Despite producing small quantities of waste on the global level,

Montenegro is waste exporting, importing and transiting country.

Data availability on illegal movement of waste is limited in the

world as in Montenegro. In official statistics of Montenegro, it is

possible to find only information on legal imports and exports of

waste, but but this does not necessarily mean that the illegal

trafficking of waste is not present in Montenegro. According to

Montenegro Statistical Office (MONSTAT), 557.635,81 tonnes of waste

were generated from industry in 2011 out of which 551.059,21 tonnes

of non-hazardous waste and 6 576.60 tonnes of hazardous waste

(Montenegro Statistical Office [MONSTAT], 2012a). 297.428 tonnes of

communal waste were collected in 2011. That is less than in 2009,

when 464.617 tonnes were collected. (MONSTAT, 2012b). MONSTAT does

not have the information of the total amount of municipal waste

produced because they are often disposed at uncontrolled landfills.

In 2008, 63 permits were issued by EPA for the import of non-

hazardous waste. »These were mostly secondary raw materials intended

for further processing, mostly scrap iron for the purposes of the

Niksic Ironworks« (Government of Montenegro, Ministry of Physical

Planning and Environmental Protection [GM MPPEP], 2009 : 108). In

2008, Montenegro exported following hazardous waste: 1.800 tonnes of

waste lead-acid accumulators; 36 tonnes of waste non-halogenated

solvents; 111 tonnes of waste consisting of, containing or polluted

by solutions or bases; 41 tonnes of waste consisting of or

containing unspecified chemicals or those whose shelf life had

expired and that possessed the characteristics of hazardous

substances; 30 tonnes of pharmaceutical waste and 100 tonnes of used

oil-filled capacitors and transformers containing PCB (printed

circuit board) (GM MPPEP, 2009).

From 1 March 2009 to 1 March 2010 EPA issued 293 permits for

transboundary movement of waste. At that time, EPA has controlled

the 281 official permits for non-hazardous transboundary movement of

waste and conducted 1 control of official permit for transboundary

movement of hazardous waste at the border crossing (EPA, nd).

Unfortunately, EPA does not report how many permits have been issued

for the export, import and transit and if there were any

irregularities in permits control. According to EPA, in the same

period Montenegro imported 1.280 pieces of packaging, 457.900 tonnes

of metal scrap and metal alloys, 10 tonnes of waste tires, 795

tonnes of waste from agriculture and food industry, 1 tonne of

chemical wastes, 64 pieces of used machines, 1 piece of used

electrical and electronic equipment and 3.800 pieces of used tires.

In the same period Montenegro exported 3 pieces of electronic chips

(used equipment), 50 tonnes of sludge and filter cakes, 50 tonnes of

waste from production, preparation and use of pharmaceutical

products, including expired medicinal and pharmaceutical products

and 5.300 tonnes of waste lead-acid batteries. Transit of waste

through Montenegro in that period included 20 pallets of packaging,

446.555 tons of metal scrap and metal alloys, 151.948 tonnes of

plastic waste, 7.800 tonnes of waste paper, cardboard and paper

products, 67 tonnes of chemical wastes, 3 pieces of used machinery,

1.406 packs, 25.809 pieces, 23 pallets and 45 tonnes of used

electrical and electronic equipment, 105.984 pieces and 14 tons of

used tires (EPA, n.d.). In 2009 Montenegro exported 3.400 tonnes of

hazardous waste. In 2010, the quantity of exported hazardous waste

increased to 8.330 tonnes (Batakovic and Vuckovic, 2011). Because

import of hazardous waste to Montenegro is prohibited by the Law on

Waste Management, there are no official data about hazardous waste

import into the country.

According to available data, in 2010 Montenegro exported: Ferrous

waste and scrap ($11,576,916); copper waste and scrap ($9,062,05);

aluminium waste or scrap ($3,493,591); Lead waste or scrap

($310,109); plastic waste, parings and scrap ($108,935); waste and

scrap of batteries and used batteries ($99,415); zinc waste and

scrap ($41,370); vegetable materials and waste ($2,657). In that

same period, Montenegro imported: Ferrous waste and scrap

($20,342,235); aluminium waste or scrap ($964,780); waste and scrap

of batteries and used batteries ($10,979); waste of man-made fibers

($6,237); plastic waste, parings and scrap ($3,696); cotton waste

($3,409); waste, parings and scrap of rubber ($2,339) (The

Observatory of Economic Complexity, 2010). Information on the

purpose of imports of waste in Montenegro is not available; however,

we can assume (by type of imported waste and industry in Montenegro)

that waste are imported primarily for the purpose of recycling or

recovery of waste and not for final disposal.

According to available data from 2007 to today, Montenegro exported

most of waste to Slovenia, Bosnia and Herzegovina and Serbia.

Montenegro also exported waste to Italy, Macedonia, Albania,

Germany, Austria and Croatia. During this period, Montenegro

imported most waste from Bosnia and Herzegovina, Slovenia, Serbia

and the Russian Federation. They also Imported waste from Greece,

China, Germany, Albania, Croatia and Italy. These are mostly sorted

waste and raw materials for further processing

(http://comtrade.un.org/db).

3 Case Study

Montenegro is despite in its Constitution defined as ecological

country, full of wild or illegal landfills. Literature review has

led us to two pivotal findings/assumptions. First, despite the large

number of illegal and unregulated landfills, waste deposited in

Montenegro is a product of the locals and domestic companies. That

means it is not a result of (illegal) waste trading. We also found

that we can not connect Montenegro to the illegal trade in waste and

illegal dumping outside their national borders. Despite written,

illegal waste trade in relation to Montenegro can neither be

discarded or confirmed. Below we'll look at the case referred to

Montenegro and waste trading. Example shows an attempt to export the

waste sand (grit) from Montenegro to Guinea.

Attempted export of hazardous grit case

Adriatic Shipyard Bijela and company Adriatic Marinas signed an

agreement on establishing a joint venture called Montenegro Yacht

Repair (Parkovic, 2012). The project foresees the construction of

center for the repair and maintenance of luxury yachts on three

hectares of land at Shipyard Bijela. Company Adriatic Marinas also

owns a marina for megayachts Porto Montenegro in town of Tivat. A

prerequisite for the construction of this center was that the

Adriatic Shipyard Bijela and Republic of Montenegro must clean or

solve the problem of large amounts of deposited grit on area of

Shipyard Bijela intended for the construction of the center. The

problem has occurred at the disposal of 27.000 cubic meters or

60.000 tons of grit (Lukovic in Petric, 2011, Tomic, 2011).

Grit by itself is not dangerous, nor does it have elevated levels of

radioactivity, but in the process of blasting ships grit accumulate

many contaminants that are in the chemical compositions of paints

and coatings and are toxic. Grit is due to toxic contaminants (scrap

of paints, coatings, metal particles and corrosion) classified as

hazardous waste (Assembly of Montenegro, Ministry of Sustainable

Development and Tourism, 2011). Montenegro does not have proper

disposal facility (landfill), so the grit cannot be properly

deposited. Therefore, Adriatic Shipyard Bijela published a tender to

choose the company that would allow the best, the cheapest and most

effective way for exportation grit abroad. Shipyard Bijela selected

and signed a contract with Croatian company Lalizas Marine, for the

exportation of the whole quantity of deposited grit from Montenegro

into Guinea. Shortly after signing the contract, on the internet

(especially on forums) speculation about the suspicious/doubtful

documents that allow the import of hazardous waste (grit) in Guinea,

have occurred. Croatian company Lalizas Marine has, in the process

of obtaining a license for grit export from Montenegro to Guinea,

submitted to the EPA, a Guinea's confirming document for hazardous

waste (grit) import. In this document, the Guinean Government

Secretary Tibou Kamara allows hazardous waste import in Guinea;

however, the document did not include a handwritten signature from

Kamara. Simultaneously, the Lalizas Marine company submitted to EPA

the contract with Guinean company Somaco Construction for transport

of waste, but also without the handwritten signature (Rekcevic in

Matovic, 2010).

Montenegro is a party of the Basel Convention, so hazardous waste

exporting company must obtain the import approval of the importing

country. After obtaining the approval or in case that the importing

country does not respond to the authorization request, it can be

presumed the importing country gave tacit consent to the import of

hazardous waste and EPA may issue a permit for the export of waste

from Montenegro. According to the newspaper Dan, in case of

exportation of grit in Guinea, all this was namely achieved but on

the basis of questionable documents (Rekcevic in Matovic, 2010).

Given the above, speculations occured on the internet (especially on

forums and articles responses) that the ship owner and exporter

intended to sink the ship with waste grit before arrival in the

importing country (i.e. Guinea). Adriatic Shipyard Bijela's

intention was to cover up a possible international scandal because

of disputed grit export from Montenegro by sinking the ship.

The director of the Environmental Protection Agency, Daliborka

Pejovic, for newspaper Dan said the company Lalizas Marine filed the

request for an export permit on hazardous waste (grit) from

Montenegro into Guinea, on 26 of August 2010. During implementation

of legal procedures to obtain an export license, on 14 March 2011,

the Croatian company notified EPA that they resign from the

requirement for a permit because they have not gained the import

permit from Guinea (Opasni otpad ostaje..., 2011). Newspaper Vijesti

has gained unofficial information according to which, at the time of

obtaining export-import licenses, EPA suspected in the validity of

Lalizas Marine documents and refused to issue a permit to Croatian

company (Lukovic in Petric, 2011).

There are different stories about grit and its exportation, so it is

difficult to judge what actually happened and what kind of intent

Montenegro or Adriatic Shipyard Bijela had on export of grit to

Guinea. No matter what the actual story is, we should be pleased

that the controversial, perhaps even illegal export of hazardous

grit did not happened. Currently, grit is in large bags stored

indoors on surfaces of Adriatic Shipyard, expected to be exported

abroad in accordance with the Basel Convention.

Legal trading of goods can often be used for conceal illegal waste

dumping and trafficking. A legal waste trade can also be a cover for

carrying out certain forms of organized crime such as weapons

trafficking. For example, the cargo train was on the way from Serbia

to Albania, carrying 16 wagons of waste for Albanian company that

deals with waste collection. The train was halted on the Albanian-

Montenegrin border, on 30th of December 2010. Inspection of wagons

showed that one of them was full of different types of ammunition

and weapons mixed with the waste. Five crew members were accused of

illegal trade in weapons and ammunition (Karadaku, 2011).

4 Conclusion

The experts are noticing that the transboundary movement of waste is

growing, which is especially applicable to hazardous waste

trafficking. Hazardous waste trafficking is often managed by

existing criminal organisations which are using the same methods,

connections and routes like for other goods, such as drugs, arms and

people (United Nations Environment Programme, GRID-Arendal

[UNEP/GRIDA], 2006). Weak institutional and legal frameworks,

corruption, insufficient controls and inadequate sanctions are the

main reasons for poor efficiency of environmental standards and an

opportunity for illegal activities. The prime victims are developing

countries and conflict zones. However, this is not only a problem of

underdeveloped and poor countries, even developed countries are

facing such challenges. For instance, criminal organizations like

Italian mafia are entering in the field of waste management market

and diverting part of the shipments toward the much more profitable

illegal market (Zoi Environment Network and GRID-Arendal [Zoi/GRID],

2012). Sometimes actors are hidden behind the legitimate waste

treatment industry and often the waste for export are labelled as

goods for recycling. »Illegal waste trade is often facilitated

through cooperation with established sectors such as import and

export firms, metal recycling and financial services. Corruption

also plays a role, for example, laboratories issuing false

certificates« (Europol, 2011 in EEA, 2012 : 29-30). According to

Europol, illegal transboundary waste movement has become one of the

fastest growing areas of organised crime. The main routes of illegal

movements of waste electrical and electronic equipment (e-waste) and

end-of-life vehicles often go via ports in North Western Europe to

West Africa and Asia. Also, important routes for hazardous waste

trafficking are going from Southern to South East Europe and the

Western Balkans (mainly Romania, Hungary and Albania) and also to

other states. Italy has become non-negligible transit point for e-

waste destined to Africa and Asia (Europol, 2011).

Large quantities of waste produced on a global level and their

transportation around the world are causing difficult, if not

impossible task for systematic monitoring of the waste chain.

Knowing that in 2010 about 24 million containers passed through the

Port of Hong Kong, about 11 million through the port of Rotterdam

and about 2.8 million through the port of Gioia Tauro and Calabria,

the biggest harbor in Italy and the Mediterranean Sea (Zoi/GRID,

2012), we soon realize that the complete control of shipments is

impossible. All this provides easier means of illegal waste trading

and other illegal activities.

It is hard to say or deny that Montenegrin organized crime groups

are operating in the field of waste trafficking because the evidence

for this does not exist. Even if the illegal waste trade is rare in

Montenegro, this does not mean that it is immune to such deviations.

Nonetheless, it is necessary to say that organized crime in

Montenegro is still highly present and active in various fields. To

this we must add the awareness that corruption (still) plays a

decisive role in Montenegro. Therefore, it can be assumed that in

Montenegro also exists a possibility that the issued licenses for

the import, export and/or transit of waste are issued unlawfully

(illegally) and/or due to corruption. It is also possible that

issued permits and waste analysis are partially or fully forged. It

is necessary to understand that the illegal waste trading does not

belong only to the domain of organized crime groups. Often, there

are actors from companies involved in the processing, recycling

and/or exporting of waste. We certainly do not intend to draw hasty

conclusions, we only want to draw attention to these possibilities.

However, we wish that Montenegro solve the problem of illegal dumps

and truly comes to life as an ecological state.

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