Published: 25.09.2026. · ISO 14001

Integrated permits for industrial installations in 2026: check whether the new Regulation covers your plant

Publisher: ConsultHQ

Regulation 75/2026 updates the activities and industrial installations subject to integrated permits, BAT requirements and emissions control in Montenegro.

Since 11 June 2026, Montenegro has applied Regulation 75/2026 on the activities and installations for which an integrated permit is issued. It is particularly relevant to larger industrial plants, energy, metal and chemical production, food processing, waste management and other activities that exceed the prescribed capacity thresholds.

For an ISO 14001 company, this is more than another rule to add to a legal register.

If an installation falls within scope, its integrated permit affects the management of emissions, waste, raw materials, energy, monitoring and process changes.

Its regulatory status should therefore be checked before a major production expansion or the introduction of new technology.

Regulation 75/2026 has applied since 11 June

The Regulation on types of activities and installations for which an integrated permit is issued was published in Montenegro's Official Gazette No. 75/2026 on 3 June.

It entered into force on 11 June 2026 and replaced the previous Regulation No. 68/2019.

It was adopted under the current Law on Industrial Emissions.

That law has been in force since 2019 and provides the basis for integrated prevention and control of industrial pollution.

The integrated permitting system was therefore not introduced for the first time in 2026. The regulatory scope of installations was updated.

An integrated permit addresses the installation's overall impact

The industrial emissions framework does not treat air, water, soil, waste and energy as entirely separate matters.

An integrated permit considers the installation's overall environmental impact.

Montenegro's Law on Industrial Emissions reflects the principles of the EU Industrial Emissions Directive 2010/75/EU, including an integrated approach, best available techniques, monitoring and inspection.

For an operator, solving one problem should not create another. For example, reducing air emissions should not shift an uncontrolled burden to waste or wastewater.

Best available techniques, or BAT, play a central role

An integrated permit is more than a list of maximum emission values.

Operating conditions for a covered installation are linked to best available techniques (BAT).

Montenegro's BAT rules include criteria such as waste minimisation, use of less hazardous substances, reuse and recycling, energy efficiency, the nature and volume of emissions, accident prevention and reduction of overall environmental impact.

This does not automatically mean buying the most expensive technology available. BAT is assessed in light of technical development, availability and the characteristics of the sector and installation.

The operator must, however, be able to show that the process is managed within the applicable regulatory framework.

The new Regulation covers energy and large combustion plants

The list includes certain energy installations.

These include combustion plants with a total rated thermal input of 50 MW or more, refining of mineral oil and gas, coke production and certain gasification, liquefaction and pyrolysis processes.

Capacity matters: the same activity does not necessarily trigger the same regulatory regime for a small installation and a large industrial plant.

The exact process and capacity therefore need to be checked before reaching a conclusion.

Metal production has different thresholds for different processes

The new list covers a range of metal production and processing activities.

They include certain steelworks, rolling mills, forges, foundries and installations treating the surface of metals or plastics by electrolytic or chemical processes.

The Regulation sets specific capacity thresholds. Some surface treatment activities, for example, fall within scope when the volume of treatment vats exceeds the prescribed level.

An activity name alone is not enough; technical installation data is needed.

Battery production appears as a separate category

The new list also includes battery production, other than exclusive assembly, once production reaches the prescribed threshold.

The Regulation specifies 15,000 tonnes or more of battery cells per year, including the cathode, anode, electrolyte, separator and casing.

This illustrates why companies should not rely only on the 2019 Regulation. New industrial technologies and changes to the regulatory framework can alter which activities need review.

Minerals and certain extraction activities may also fall within scope

The Regulation covers certain production of cement, lime and magnesium oxide, glassmaking, melting mineral substances and ceramics production above specified capacities.

It also lists industrial extraction and treatment of certain ores, including bauxite, copper, iron, lithium, nickel, lead and zinc.

For an investor or operator, an environmental regulatory review should precede a significant capacity change. An installation that was previously below a threshold may enter a different regime after expansion.

Chemical production has broad coverage

The list includes industrial production of various organic and inorganic chemicals.

It also covers certain polymers, synthetic fibres, synthetic rubber, paints, pigments and surfactants, as well as some production of fertilisers, plant protection products, biocides, pharmaceutical products and intermediates, and explosives.

For companies in these sectors, both the Chemicals Law and the Industrial Emissions Law may be relevant, but they serve different purposes.

One governs chemicals and their regulatory status; the other addresses the overall industrial impact of a covered installation.

Waste treatment has its own integrated permit thresholds

Certain large waste treatment and disposal installations fall within the integrated permit system.

The list includes some hazardous waste operations above 10 tonnes per day, incineration and co-incineration, large non-hazardous waste treatment facilities, landfills and certain hazardous waste storage activities.

This is separate from the general duties under the Waste Management Law. A business may have waste management obligations without needing an integrated permit.

An integrated permit applies to installations and activities that meet the Regulation's specific categories and thresholds.

Large food processing plants may also be covered

This matters to food industry clients as well as other industrial operators.

The Regulation covers certain slaughterhouses and large installations processing food and animal feed.

For exclusively animal raw materials other than milk, it specifies finished-product capacity above 75 tonnes per day. For exclusively plant raw materials, the threshold is above 300 tonnes per day, subject to a separate seasonal threshold for certain installations.

For exclusively milk processing, it specifies intake above 200 tonnes per day as an annual average.

HACCP and food compliance are therefore not necessarily the only regulatory systems relevant to a large food producer.

Slaughterhouses above the threshold are also listed

The Regulation specifies a carcass production capacity above 50 tonnes per day for slaughterhouses.

Such a facility may simultaneously face requirements relating to HACCP and food safety, waste and by-products, emissions, water and an integrated permit.

A large food plant should therefore be assessed through a wider compliance map, not solely its HACCP documents.

Textiles and leather processing may be covered according to capacity

The list includes pretreatment or dyeing of textile fibres or textiles with production capacity above 10 tonnes per day.

It also includes leather tanning above the prescribed capacity.

Environmental compliance in these industries is often discussed only in terms of wastewater and chemicals. For larger installations, the need for an integrated permit should be checked first.

Organic solvents can trigger a separate category

Certain surface treatment of substances and products using organic solvents is also listed.

For activities such as printing, coating, degreasing, painting, cleaning and impregnation, the Regulation sets a consumption threshold above 150 kg per hour or 200 tonnes per year.

This may affect companies in many sectors. A company's name may not suggest chemical production, while its technical process still places it within scope.

Intensive poultry and pig farming receives more precise treatment

The new Regulation also addresses certain large intensive poultry and pig farming installations.

It lists thresholds of more than 40,000 places for poultry, 2,000 places for pigs over 30 kg, or 750 places for sows.

It also includes rules for nearby installations controlled by the same operator or economically or legally connected operators.

This prevents a single large activity from being artificially divided into smaller units merely to avoid a threshold.

Capacities may need to be added together

In specified circumstances, capacities of multiple activities within the same industrial sector, installation or site may be added together to determine whether a threshold is reached.

An operator should not assess each line in isolation if the Regulation requires combined capacity.

Screening should therefore use the installation's actual technical layout.

Article 45 of Air Protection Law 117/2026 exempts an operator from a separate emissions permit where another law requires an integrated permit or EIA consent. Applicable emissions conditions and monitoring still apply; the regime depends on the installation. See the Air Protection Law guide.

An integrated permit and EIA are different procedures

Environmental impact assessment (EIA) and an integrated permit serve different purposes.

EIA primarily assesses a specific project's impact before it is carried out. An integrated permit governs operating conditions for an installation covered by the industrial emissions framework.

The Industrial Emissions Law links the procedures for relevant installations, but they should not be presented as the same process.

An investor should map all applicable regulatory steps before starting a project. More than one procedure may apply.

ISO 14001 does not replace an integrated permit

ISO 14001:2026 provides an environmental management system. An integrated permit is a statutory regulatory instrument.

A company can hold ISO 14001 certification and still have a duty to obtain and maintain an integrated permit.

A well designed ISO 14001 system can, however, help the organisation manage permit conditions, including:

• monitoring;
• emissions;
• waste;
• resources;
• incidents;
• legal obligations;
• internal reviews; and
• corrective actions.

The permit then becomes part of the operational environmental management system rather than remaining only with a legal or environmental department.

Permit conditions need assigned owners

Problems arise when a permit exists but plant managers do not know which requirements belong to their processes.

Relevant conditions should therefore be assigned to functions. One may belong to maintenance; another to the laboratory, production or the person responsible for emissions monitoring.

ISO 14001 documentation can use the permit as a specific source of compliance obligations. This reduces the risk of missing a deadline or measurement because no one owns it.

BAT conclusions belong in regulatory monitoring

Montenegro's ministry publishes BAT conclusions for different sectors on its official pages.

They include food, beverage and milk processing, cement, waste treatment, large combustion plants, metals and other sectors.

For a covered installation, following the Law and the permit number alone is insufficient. Relevant BAT documents can affect the technical and emission requirements expected in the sector.

They should therefore be included in regulatory monitoring.

A capacity change can alter an installation's status

A company may currently be below a regulatory threshold. Production expansion can take it above that threshold.

Regulation 75/2026 should therefore be checked before capacity is increased.

Change management in a larger industrial company should include environmental compliance screening alongside the financial and technical assessment of a project.

Existing installations should review their status under the new Regulation

A company that determined its regulatory status in 2019 should not assume that nothing has changed.

Regulation 75/2026 replaced the previous list. New or more precisely defined categories deserve particular attention, including battery production, certain mining activities and some metallurgical processes.

The safest approach is to compare the actual activity and capacity with the current annexes to the Regulation.

What industrial companies should check now

First, establish whether the specific installation falls within Regulation 75/2026.

The review should cover:

• the type of industrial activity;
• production capacity;
• combined capacity of connected activities;
• any existing integrated permit;
• planned changes and expansions;
• relevant BAT conclusions;
• existing emissions monitoring;
• permitted emission limit values;
• waste and wastewater duties;
• closure or site restoration conditions where relevant; and
• the ISO 14001 register of compliance obligations.

An installation outside this Regulation may still have other environmental permits and duties. An integrated permit is not the industry's only regulatory regime.

ConsultHQ can connect integrated permit duties with ISO 14001

For industrial clients, a common difficulty is that each environmental requirement lives in a separate document.

EIA may contain one set of measures, an integrated permit another, ISO 14001 a third, while operations use a fourth set of instructions.

Through ISO 14001 implementation and a regulatory gap analysis, ConsultHQ can connect permit conditions, relevant BAT requirements, monitoring and existing operational controls.

Formal work to obtain an integrated permit must follow the statutory procedure and involve the appropriate authorised participants where required.

Our role is to help keep obligations within a functioning management system after the permit is issued.

Related pages: ISO 14001 in Montenegro, ISO standards for factories, gap analysis and environmental impact assessment.

Official sources: Official Gazette: Regulation 75/2026; Official Gazette: Industrial Emissions Law.

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