Packaging waste in Republika Srpska: duties for small food and hospitality businesses

This article explains packaging and packaging waste duties in Republika Srpska for small food producers, guesthouses, restaurants and other tourism businesses. Two things must be kept apart: the duty of the "isporučilac" (supplier, the business that first places packaging or packaged goods on the market) and the general duty of every waste owner to hand waste to an authorised party. It describes the Law on Waste Management as amended by Službeni glasnik RS br. 70/20 and the Uredba in Službeni glasnik RS br. 24/21.

In short

• The obliged party is the isporučilac: a legal entity or entrepreneur that first places packaging or packaged goods on the Republika Srpska market, whether or not it is also the producer, importer, packer or filler.
• A report on packaging for the previous calendar year goes to the Fond za zaštitu životne sredine i energetsku efikasnost RS (Environmental Protection and Energy Efficiency Fund) by 20 February of the current year.
• Fee coefficients and targets do not apply to small yearly quantities: up to 100 kg paper, 300 kg glass, 30 kg metal, 80 kg plastic, 100 kg wood and 50 kg all other materials.
• You may transfer packaging waste management by contract to an operator holding a Ministry permit, but a business that has transferred its duty is still named among those who give the Fond the annual report, so confirm with the operator and the Fond who submits it.
• The Uredba (Government Regulation) sets fines of 2,000 to 10,000 KM for a legal entity and 2,000 to 6,000 KM for an entrepreneur who does not give the Fond accurate data.

Who it applies to

• Producers who sell packaged products (bottled rakija and wine, cheese, honey, ajvar, oil, jams) and those who fill or pack them.
• Importers and wholesalers who first place packaging or packaged goods on the RS market.
• The Uredba also covers packaging waste from crafts and services. The inspectorate names hospitality among the activities whose packaging waste must be handled under the law.
• Returnable and long-life packaging is outside the Uredba.
• A restaurant or guesthouse that only buys already packaged goods from RS suppliers is normally not the first to place that packaging on the market. If you are unsure about your case, ask the Fond before the deadline.

What to do

1. For the previous year, measure or estimate the packaging you placed on the market by material: paper/cardboard, glass, metal, plastic, wood, other.
2. The report is submitted on Form 1 (Supplier report on packaging and packaging waste) with a specification: trade name of the product, type of packaging (primary, secondary, tertiary), material quantity per unit and quantities sold. Compare your quantities with the thresholds above: if you are below the threshold for a material, the fee for that material is calculated without coefficients and targets. Confirm with the Fond whether you still have to report in that case.
3. Submit the report to the Fond by 20 February. The Fond issues a decision on the fee, or on exemption from the fee.
4. Pay the fee as decided (the Fond issues three payment slips) and send proof of payment to the Fond.
5. Alternative: sign a contract with an operator that holds a Ministry permit, who then takes over packaging waste management. A business that has transferred its duty to an operator is still mentioned in the annual reporting to the Fond (art. 63g(4) of the Law), so confirm with the operator and the Fond who submits the report.
6. General rule: a waste owner hands waste to a party engaged in waste management. Responsibility ends when that party takes it over and certifies the waste movement document. For everyday municipal waste (mixed, paper, glass, biowaste) ask your municipal utility how separation and collection are organised.

Deadlines and amounts

• Report: by 20 February for the previous year.
• The Fond sets the fee by decision. It consists of a registration fee, a general-objectives fee and a specific-objectives fee. Check the coefficients for the relevant year with the Fond.
• Fines under the Uredba: legal entity 2,000 to 10,000 KM, responsible person 1,000 to 2,000 KM, entrepreneur 2,000 to 6,000 KM. These amounts come from the Uredba; the Law on Waste Management has its own penal provisions, so check the amounts with the Fond or the Inspectorate.
• According to the Republika Srpska Inspectorate statement of 25 May 2026, the Tržišna inspekcija (Market Inspection) carried out about 150 packaging waste management controls in 2025 and imposed fines totalling 280,000 KM for inaccurate reported quantities. It states that its aim is timely reporting, not punishment.

Where to go

• Fond za zaštitu životne sredine i energetsku efikasnost RS, Kralja Alfonsa XIII 21, Banja Luka: ambalaza@ekofondrs.org, tel. 051/231-350.
• Inspektorat Republike Srpske (Republika Srpska Inspectorate), whose Market Inspection supervises packaging rules.
• Your municipal utility company (Trebinje, Bileća, Gacko, Ljubinje, Nevesinje, Berkovići) for municipal waste collection.

Laws and sources

Described according to the Law as amended by Službeni glasnik RS br. 70/20 and the Uredba in Službeni glasnik RS br. 24/21. Before filing, check with the Fond that no later amendment exists.

• Uredba o upravljanju ambalažom i ambalažnim otpadom (Službeni glasnik RS br. 24/21), arts. 19, 25, 28, 29
• Law amending the Law on Waste Management (Službeni glasnik RS br. 70/20), art. 14 (20 February deadline) and art. 6 (amended art. 37 of the Law: waste owner duties)
• Law amending the Law on Waste Management (Službeni glasnik RS br. 16/18), art. 63g (thresholds)
• Inspektorat Republike Srpske: cooperation with the Fond on packaging waste (25 May 2026, in Serbian)