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.
5 Bibliography
Assembly of Montenegro, Ministry of Sustainable Development and
Tourism. (2011). Odgovor na poslaničko pitanje poslanika Slavena Radunovića.
Podgorica, 23. 7. 2011, broj 01-922/6. Retrieved from
http://www.skupstina.me/cms/site_data/POSLANI%C4%8CKA
%20PITANJA/JUL/odgovori/Slaven_Radunovic_odg_1.PDF
Bataković, M., Vučković, N. (2011). National Review of the Application
of Environmental Indicators. Retrieved from
http://www.unece.org/fileadmin/DAM/stats/documents/ece/ces/ge.33
/2012/mtg1/Montenegro.pdf
Constitution of Montenegro. (2007). Official Gazette of Montenegro, (1/07).
COWI. (2012). Environmental and Social Impact Assessment of National Hazardous
Waste Disposal Facility: World Bank Esia and Safeguard Study for National Waste
Disposal Facility. Retrieved from
http://www.arhuscg.me/wp-content/uploads/2012/07/20120725_Vesion
_After-last-consultation_ESIA-National-hazardous-waste-site1.pdf
Environmental Protection Agency of Montenegro. (n.d.). Bilten: Zaštita
životne sredine. Retrieved from http://www.osce.org/me/node/76870
European Commission . (2011). Commission staff working paper: Montenegro 2011
progress report. Retrieved from
http://ec.europa.eu/enlargement/pdf/key_documents/2011/package/m
n_rapport_2011_en.pdf
European Environment Agency. (2010). The European environment – state outlook
2010: Montenegro: Country profile. Retrieved from
http://www.eea.europa.eu/soer/countries/me/soertopic_view?
topic=country%20introduction
European Environment Agency. (2012). Movements of waste across the EU's
internal and external borders. EEA Report, No 7/2012, European
Environment Agency, Copenhagen.
European Topic Centre on Resource and Waste Management (2008).
Transboundary shipments of waste in the EU: Developments 1995-2005 and possible
drivers: ETC/RWM Technical Report 2008/1. Retrieved from
http://scp.eionet.europa.eu/publications/Transboundary
%20shipments%20of%20waste%20in%20the%20EU/wp/tech_1_2008
European Union Network for the Implementation and Enforcement of
Environmental Law. (2006). IMPEL-TFS Enforcement Actions: Enforcement of
EU Waste Shipment Regulation: “Learning by doing”. Retrieved from
http://www.ies.be/files/repo/IMPEL-
TFS_enforcement_project_I_final_report_June_2008.pdf
Europol. (2011). OCTA 2011: EU Organised Crime Threat Assessment. Retrieved
from
https://www.europol.europa.eu/sites/default/files/publications/o
cta_2011_1.pdf
Government of Montenegro, Ministry of Physical Planning and
Environmental Protection. (2009). Questionnaire: Information requested by
the European Commission to the Government of Montenegro for the preparation of
the Opinion on the application of Montenegro for membership of the European Union:
27 Environment. Retrieved from
http://www.questionnaire.gov.me/O/Pdf/C27.pdfKaradaku, L. (21. 2. 2011). U regionu jačaju zajednički napori
protiv ilegalne trgovine. SETimes (online). Retrieved from
http://setimes.com/cocoon/setimes/xhtml/bs/features/setimes/arti
cles/2011/02/21/reportage-01
Kostić-Mandić, M. (2011). Harmonisation of the Montenegrin
Environmental Legislation with the European Union Law. Natura
Montenegrina, 10(3), 323-333.
Law on Environment. (2008). Official Gazette of Montenegro, (48/08).
Law on ratification of the Basel Convention on transboundary
movements of hazardous wastes and their disposal. (1999).
Official Gazette FRY, International Contracts, (2/99).Law on Waste Management. (2011). Official Gazette of Montenegro, (64/11).
Luković, S., Petrić, R. (18. 12. 2011). Obaveza države prema
milijarderu: Manku čiste plac za remont jahta, a Baranima dovoze
tone grita. Vjesti (online). Retrieved from
http://www.vijesti.me/vijesti/manku-ciste-plac-remont-jahti-a-
baranima-dovoze-tone-grita-clanak-52225
Medix. (2008). The Feasibility Study for the Construction of a Regional Sanitary Landfill
in the Municipality of Berane. Retrieved from
http://ebookbrowse.com/feasibility-study-berane-eng-doc-
d136159353
Montenegro Statistical Office. (2012a). Amount of waste generated from
industry 2011. Retrieved from
http://www.monstat.org/userfiles/file/ziv%20sredina/Quantities
%20of%20waste%20generated%20from%20industry%20PDF.pdf
Montenegro Statistical Office. (2012b). Municipal waste in Montenegro 2011.
Retrieved from http://www.monstat.org/userfiles/file/ziv
%20sredina/eng%20OT%20KOM-03%2029%2006%202012%20%20PDF.pdf
Opasni otpad ostaje u Bjeloj: Daliborka Pojović demantovala Vladu.
(20. 12. 2011). Dan (online). Retrieved from
http://www.dan.co.me/?nivo=3&rubrika=Periskop&datum=2011-12-
20&clanak=312189
Perković, N. ( 23. 1. 2012). Kanadski biznismen Piter Mank kreće sa
novim investicijama u Boki. Pobjeda (online). Retrieved from
http://www.pobjeda.me/2012/01/23/kanadski-biznismen-piter-mank-
krece-sa-novim-investicijama-u-boki/
Rakčević, M. V., Matović, K. (8. 11. 2010). Izplatili 2,5 miliona na
osnovu sumnjivih ugovora. Serbian Forum. Retrieved from
http://serbianforum.org/crna-gora/157995-isplatili-2-5-miliona-
na-osnovu-sumnjivih-ugovora.html
Republic of Serbia, Ministri of Environmrnt and Spatial Planning.
(2011). Technical Assistance for the Hazardous Waste Management Facillity –
Republic of Serbia: Task 1.1.4 – Options for appropriate Cross-border Cooperation
Opportunities – draft version. Retrieved from
http://www.hwmf.rs/en/Documents/Task1/T1-1-4_Cross-border
%20Cooperation%20Opportunities_final.pdf
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. (2010). Official Gazette of
Montenegro, (71/10).
The Observatory of Economic Complexity. (2010). Learn More About: Trade in
Montenegro. Retrieved from
http://atlas.media.mit.edu/country/mne/
The Decision on the Control List for Export, Import and Transit of
Goods. (2011). Official Gazette of Montenegro, (10/11).
Tomić, R. (19. 1. 2011). Gvineja je »daleko« još mjesec i po.
Pobjeda (online). Retrieved from
http://www.vijesti.me/vijesti/manku-ciste-plac-remont-jahti-a-
baranima-dovoze-tone-grita-clanak-52225
United Nations Environment Programme and GRID-Arendal. (2006). Vital
Waste Graphics 2. Retrieved from
http://www.grida.no/publications/vg/waste2
Vasiljevic, M. (n.d.). Challenges Facing Montenegro. Retrieved from
http://sector.rec.org/sector1/assistance/urban/montenegro.pdf
Waste Management Plan. (2008). Official Gazette of Montenegro, (16/08)Workshop on Illegal Traffic. (2006). The 16th Regional Workshop on Illegal
Traffic. Bratislava, Slovakia, October 2006. Retrieved from
http://www.sazp.sk/bcrc/script/detaily/activities8.php
Zoi Environment Network and GRID-Arendal. (2012). Vital Waste Graphics 2.
Retrieved from http://www.grida.no/publications/vg/waste3/
Top Related