Published: 25.09.2026. · ISO 14001

Amendments to Montenegro's Waste Management Law in 2026: what businesses should check

Publisher: ConsultHQ

Law 128/2026 expands producer responsibility, sets deadlines for packaging and textiles, and strengthens waste records and planning.

Montenegro has applied the amended Waste Management Law since 8 September 2026. Law 128/2026 provides more detail on extended producer responsibility, packaging, electrical and electronic equipment, batteries, textiles, food waste, biowaste and reporting. Businesses need better records and clearer evidence of where waste goes.

This is an amendment to an existing system. Law 34/2024 already introduced extended producer responsibility and major waste-management changes. The 2026 amendments clarify and extend that framework and set deadlines for particular product and waste streams.

For companies using ISO 14001, the legal obligations register, waste-management plan, records and operational controls should be reviewed against the amended law, rather than the 2024 text alone.

Law 128/2026 entered into force on 8 September 2026

The amendments were published in the Official Gazette of Montenegro, issue 128/2026, on 31 August and entered into force on 8 September 2026. They amend the Waste Management Law 34/2024.

Before adoption, the Ministry highlighted extended producer responsibility, packaging, electrical and electronic equipment, batteries, textiles, food waste, biowaste, records, transboundary waste movements and stronger oversight. The changes therefore concern more than specialist waste operators: producers, importers and companies placing relevant products on the Montenegrin market may also be affected.

Extended producer responsibility becomes more specific

One major change concerns EPR: extended producer responsibility. The amended Article 15 covers producers placing the following on Montenegro's market:

• electrical and electronic equipment;
• vehicles;
• batteries and accumulators;
• tyres;
• packaging;
• certain single-use plastic products;
• fishing gear containing plastic;
• textile products.

Producer responsibility is more than paying a fee. Depending on the product and applicable rules, it may involve organising or financing waste collection and treatment, meeting reuse and recycling targets, informing the public, collecting data and reporting. Companies producing or importing these products should treat EPR as a distinct compliance topic.

A “producer” is not necessarily a domestic factory

The amendments clarify that a producer may be a business or entrepreneur that makes, processes, treats, sells or imports products that become waste after use. Distance selling is expressly mentioned. Importers and online sellers should therefore not assume that a lack of manufacturing in Montenegro removes EPR duties. The relevant question is who places the product on the Montenegrin market.

Foreign producers use an authorised representative

Where a producer is not registered in Montenegro, the law provides for an authorised representative to be responsible for duties under the extended producer responsibility programme. International suppliers, distributors and importers should identify which party has producer status and which party fulfils each EPR duty.

Packaging has a dedicated producer register

A packaging producer established in Montenegro, and the authorised representative of a producer established elsewhere, must be entered in the packaging producers register kept by the Environmental Protection Agency. The register covers the types of packaging placed on the market and fulfilment of relevant duties. Further government rules are to specify details of the register and organised collection and treatment systems.

This matters to packaging manufacturers, food producers placing packaged goods on the market, importers and other businesses that may meet the law's definition of a producer.

The packaging EPR programme must be established by the end of 2027

The law sets 31 December 2027 as the deadline for establishing the packaging extended producer responsibility programme. Businesses should not interpret that deadline as a reason to postpone all preparation: a workable system needs registration, reliable quantity data, an organised scheme and implementing rules. Companies placing significant quantities of packaging on the market can start by checking their data now.

Electronics and batteries have a deadline at the end of 2030

The amended law sets 31 December 2030 as the deadline for EPR programmes for electrical and electronic equipment and batteries. It also gives more detail on collection and recycling targets for certain streams. Producers and importers should track the implementing regulations as these systems are put into operation.

Textiles gain a dedicated EPR system

The amendments introduce a separate framework for textile waste. Textile producers and authorised representatives are to be registered and bear the costs of an organised take-back, collection and treatment system. The textile EPR programme must be established by 31 December 2030. Producers, waste operators, local authorities and reuse organisations are among the relevant participants.

EPR calls for more reliable data and reporting

The amendments establish an EPR information system within the environmental information system. Data include participants in organised schemes, quantities of products placed on the market, waste collected and treated, and annual reports.

If a company cannot reliably determine the annual quantities of packaging or other relevant products it places on the market, future reporting will be harder. Product and packaging data become part of environmental compliance, not merely commercial records.

Organised EPR systems need data-quality controls

Organised systems must have suitable organisational and financial capacity and internal procedures to control internal management and the quality of collected data. Poor quantity data can lead to inaccurate regulatory reports or financial contributions. Data controls therefore matter alongside physical control of waste flows.

Financial contributions may reflect product characteristics

Within collective systems, producer contributions may differ according to a product's durability, repairability, potential for reuse and recycling, and presence of hazardous substances. The rule connects product design with the future cost of its waste and may influence packaging and product-development decisions over time.

Plastic bottles have phased collection targets

Two years after the packaging EPR programme is established, 25% by mass of relevant plastic bottles placed on the market in the reference year must be collected separately; after four years, the target is 50%. The packaging programme and return system for single-use plastic bottles are phased in. The law also links the ultimate target timetable to Montenegro's accession to the EU. Drinks producers and other major users of plastic packaging should monitor implementation.

The amendments introduce national food-waste reduction targets

The law sets national targets for 31 December 2035. In processing and production, the target is at least a 10% reduction against the average annual waste generated in 2027–2029. In retail, distribution, restaurants, hospitality and households, the target is at least 30% per capita against the same baseline.

These are national targets. They do not automatically impose an individual 30% reduction duty on each restaurant today. Specific measures and policies will determine how they are implemented.

Food donation receives greater attention

Measures to reduce food waste include encouraging donation and other redistribution of food for human consumption. Food use for people takes priority over use as animal feed or in non-food products. This connects with Montenegro's Food Hygiene Regulation 91/2026, which addresses hygiene during food redistribution. Hotels, retailers and producers should consider how they manage usable surplus food.

Separate collection of biowaste becomes more important

The amendments add municipal biowaste to the streams for which separate collection is relevant. Where separate management is available, organic waste should not simply be mixed with general municipal waste. This is an increasingly practical issue for hotels, restaurants, food retailers and food manufacturers.

Waste-management plans must follow business changes

For relevant waste producers, the amended law requires a review of the waste-management plan without delay and no later than 30 days after a significant change affecting the type or quantity of waste or how it is managed. The law specifically mentions changes to:

• the technological process;
• the company collecting or treating waste;
• other circumstances material to waste management.

The Agency may also require a review to check whether a plan matches actual operations and the law.

The plan should therefore be maintained when operations change, not merely when a scheduled renewal date arrives.

Changing a waste collector can trigger a plan review

A business may appoint a new waste contractor for commercial reasons. If this changes the way waste is managed, it should check whether the plan must be reviewed. Procurement and environmental compliance teams should include this question in their change process.

The original waste producer retains responsibility for final treatment

The underlying law already provides that handing waste to another party does not automatically end the original producer's responsibility for proper recovery or disposal. A contractor's invoice is not enough on its own. Businesses should check the operator's authorisation and retain a documentary trail for each relevant waste stream, especially hazardous waste.

Illegally discarded waste may affect a site owner

The amendments clarify the prohibition on dumping waste in the environment or at unregulated sites. If the owner of illegally discarded waste is unknown, the duty to remove it may fall on the owner or user of the land or premises. Businesses with large sites, warehouses or industrial grounds should therefore monitor their premises.

Waste-facility operators face stronger incident-reporting duties

The amendments add offence provisions for waste-management facilities. An event that may affect facility stability or cause a significant adverse environmental impact must be reported without delay and within 48 hours of becoming known. An internal emergency plan must be applied where relevant. This is a narrower duty for waste-facility operators, not for every business generating waste.

What businesses should check now

The amendments do not mean every company needs an entirely new waste-management system. First establish where the business fits within the amended framework. Check:

• whether the company has producer status under EPR rules;
• which products it places on the Montenegrin market;
• quantities of packaging and other relevant products;
• the quality of data needed for registers and reporting;
• the current waste-management plan and any changes requiring revision;
• waste-collector and treatment contracts and authorisations;
• records of waste types and quantities;
• biowaste and food-waste flows, where relevant;
• the ISO 14001 legal obligations register.

For packaging producers and companies placing packaged products on the market, the packaging EPR programme due by the end of 2027 is a particular priority.

Link ISO 14001 to the amended law

ISO 14001:2026 requires organisations to identify and monitor relevant compliance obligations. Where applicable, Law 128/2026 should be reflected in the ISO 14001 legal obligations register. It may affect:

• environmental aspects;
• operational controls;
• waste contractors;
• waste-reduction objectives;
• documentation;
• change management.

This does not require a company to seek a new certificate. A functioning ISO 14001 system should support a controlled response to such regulatory changes.

ConsultHQ connects the amended law to practical waste controls

The main risk is overlooking the few amendments that directly affect a company's business model. Through ISO 14001 and a regulatory gap analysis, ConsultHQ can review EPR status, the waste-management plan, records, contracted operators and procedures against Law 34/2024 as amended by 128/2026.

For packaging producers and other companies placing products on the market, the review may also cover the data needed for the forthcoming EPR programme. The aim is to translate the law into clear responsibilities and workable processes.

Related services and articles: food packaging, ISO 14001, gap analysis and the new Law on Chemicals.

Official sources: Official Gazette: amendments in Law 128/2026; Official Gazette: original Law 34/2024; Ministry of Ecology: adoption announcement.

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