Plants listed in Rulebook 124/12 need an environmental permit. The municipality or city issues it under Article 3 for plants below the Article 2 thresholds, and the Ministry of Spatial Planning, Construction and Ecology for larger plants and projects needing an impact assessment. A licensed legal entity prepares the evidence. The permit is valid for 5 years.
An environmental permit (ekološka dozvola) is an administrative decision that sets the measures a plant must take to protect air, water and soil. It is required for the plants listed in the Rulebook on plants that may be built and put into operation only with an environmental permit. Whether your facility is on that list depends on the type of activity and its capacity. Ask the competent authority to confirm this in writing.
In short
- The Law on Environmental Protection (Zakon o zaštiti životne sredine) requires the permit. The list of plants is in the Rulebook (Pravilnik) on plants that may be built and put into operation only with an environmental permit (Službeni glasnik RS, No. 124/12).
- A municipality or city issues the permit under Article 3 of the Rulebook, for plants whose size is below the thresholds in Article 2. The Ministry of Spatial Planning, Construction and Ecology (Ministarstvo za prostorno uređenje, građevinarstvo i ekologiju) issues it for plants under Articles 2, 4, 5 and 6 of the Rulebook and for projects that need an environmental impact assessment.
- The application must include evidence prepared by a legal entity licensed for environmental protection work.
- The permit is issued for 5 years. Renewal is requested 3 months before it expires.
- Fees and deadlines differ between municipalities. Check them with the competent department.
Who it applies to
The Rulebook covers, among others, facilities in agriculture, the food industry, tourism and entertainment. Not every farm or processing plant needs a permit. It depends on the type of activity and the threshold, for example the number of animals per species or the processing capacity.
Article 2 of the Rulebook sets the thresholds above which the Ministry is responsible, and the municipality or city acts under Article 3. Before you build, check the exact thresholds for your activity with your municipality or the Ministry and ask for a written answer on whether your facility needs a permit and which authority is responsible.
Examples from practice: under Article 3 of the Rulebook, the Bijeljina city administration issued a permit in 2019 for an already built fattening farm for 190 young cattle, and in 2021 for a built barn for 80 dairy cows. For a cattle fattening farm with 492 head per cycle in Novo Selo, Šamac municipality (investor GOLD-MG d.o.o. of Donji Žabar), the Ministry ruled in decision No. 15.4.1-96-33/25 of 29 May 2025 that the permit procedure is run by the Ministry. In September 2026 the Trebinje city administration issued permits for a bakery and for a monastery estate building in Tvrdoš: an oil mill with a storeroom, oil tasting rooms and facilities of the monastery winery.
What to do
- Ask your municipality or city for a written answer on whether your facility needs a permit and whether it falls under the municipality or the Ministry. In Trebinje this is the Odjeljenje za komunalno-inspekcijske poslove (Department for Communal and Inspection Affairs) of the City Administration, which issued both 2026 permits.
- Hire a legal entity licensed for environmental protection work to prepare the evidence required by Article 85 of the Law, in two copies.
- Submit the application on the department's form. For a new plant, attach the location conditions (lokacijski uslovi); for an existing one, the use permit (upotrebna dozvola). Add a copy of the cadastral plan. If the location conditions require it, you must have the environmental permit before you apply for a building permit.
- The authority informs the public with a notice on its notice board and website for 30 days. Anyone interested can send a written opinion.
- The authority issues a decision (rješenje). In Trebinje, a bakery applied on 27 July 2026 and the decision was issued on 14 September 2026. For the Tvrdoš building, the application was filed on 7 August 2026 and the decision issued on 9 September 2026.
- To renew, you attach an emission measurement report, the environmental inspector's record and a certified statement by the responsible person. This is set by the Rulebook on revision and renewal of environmental permits (Službeni glasnik RS, Nos. 28/13 and 104/17).
Deadlines and amounts
- Validity: 5 years. Renewal application: 3 months before expiry.
- Example of a local fee: the City of Prnjavor charges BAM 50 to issue a permit and BAM 50 to renew it, and decides within 45 days of receiving a complete application. Other municipalities may charge different amounts and set different deadlines.
- The price for preparing the evidence is not regulated. You agree it with the licensed legal entity.
Where to go
- City of Trebinje, Gradska uprava (City Administration), Odjeljenje za komunalno-inspekcijske poslove, Vuka Karadžića 2, tel. 059/274-400: trebinje.rs.ba
- For plants under the Ministry: Ministarstvo za prostorno uređenje, građevinarstvo i ekologiju, Trg Republike Srpske 1, Banja Luka: vladars.rs
- Registering premises for food production is covered in the article "Registering or approving a food business premises in Republika Srpska: who decides and the steps".
Laws and sources
- Trebinje city administration notice of the decision on an environmental permit for a bakery, 28 September 2026 (cites the Law on Environmental Protection, Službeni glasnik RS Nos. 71/12, 79/15 and 70/20, and Article 3 of the Rulebook, No. 124/12)
- Trebinje city administration notice of the decision on an environmental permit for a monastery estate building in Tvrdoš, 11 September 2026
- Environmental permit guide, City of Prnjavor
- Evidence for a permit application for a cattle fattening farm in Novo Selo, Šamac municipality, July 2025, published on the website of the Ministry of Spatial Planning, Construction and Ecology
- Bijeljina city administration decision on an environmental permit for a barn for 80 dairy cows, 6 May 2021
- Bijeljina city administration decision on an environmental permit for a cattle fattening farm, 13 May 2019
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