Beekeeping in Republika Srpska: apiary registration, honey room and selling honey

This article explains what a beekeeper in Republika Srpska must do to keep bees, extract honey and sell it legally. It applies to beekeepers, including those who offer honey to guests on rural farms.

In short

• Registration of the beekeeper and apiary is mandatory: the application goes to the Ministry within 30 days of placing the bees.
• The apiary must display a registration plate, and colony numbers are reported twice a year (counts as of 31 March and 30 September). If you do not submit the count, the Ministry may revoke your registration, and failing to report is also an offence.
• A facility where honey from your own apiary is extracted, filled and stored is registered with the Ministry and must have a room used exclusively for handling honey. Exception: selling the entire quantity directly to final consumers at the place of production.
• The honey label must state the country where the honey was collected.
• For offences under the Law on Beekeeping (unregistered apiary, missing colony counts, apiary placed too close to buildings or roads) the original text of the Law (Article 23) sets fines of 500 to 1,500 KM for an individual, 2,000 to 6,000 KM for an entrepreneur (preduzetnik), 5,000 to 15,000 KM for a legal person and 1,000 to 3,000 KM for the responsible person in a legal person. The 2023 amendment (17/23) may have changed these amounts, so check them with the Ministry before paying or appealing.

Who it applies to

All natural and legal persons who keep bees or trade in bees and bee products. Facility registration concerns those who sell honey away from the place of production (markets, delivery, shops, restaurants) or fill and pack honey for others. If you sell any part of the quantity elsewhere, the direct-sale exemption does not cover the whole quantity. If you are unsure whether sales to guests at accommodation away from the apiary count as the place of production, ask the Ministry or the veterinary inspection.

What to do

1. Enter the apiary in the Register. Apply to the Ministarstvo poljoprivrede, šumarstva i vodoprivrede (Ministry of Agriculture, Forestry and Water Management) within 30 days of placing the apiary. Attach proof of ownership or possession of the plot, or, if the plot is not yours, the owner's consent or a lease contract.
2. You receive a decision and a plate. The minister issues a decision on entry, after which the Ministry issues a registration plate. Display it in a visible place. A sign with the owner's name, address and phone number must also be visible.
3. Respect the distances. An apiary must be more than 20 m from houses, business premises, livestock buildings, public roads and other people's land (less only from your own buildings), more than 100 m from schools, kindergartens and playgrounds, more than 50 m from motorways, railways and airports, and more than 300 m from production and processing plants and tourist facilities during the tourist season. The own-building exception applies only to the 20 m rule, so the 300 m rule also covers your own tourist accommodation. Under the original text of the Law (Article 8), two mobile apiaries must be more than 200 m apart, a stationary and a mobile one more than 300 m apart, and an apiary must be more than 3 km from a selection centre. The 2023 amendment (17/23) may have changed these distances, so check them with the municipal agriculture department or the Ministry.
4. Report colony numbers. Submit the count (31 March and 30 September) within 15 days to the municipal agriculture office on the prescribed form, or through your beekeepers' association if you are a member. If an apiary has no colonies, return the plate to the Ministry within 30 days. If you do not submit the data, the Ministry may revoke the registration decision.
5. Moving an apiary to pasture. You need the written consent of the landowner or user, a decision of approval from the agriculture office of the municipality you move to (issued within 15 days, valid for one calendar year, with a grazing order) and a veterinary health certificate for the bees not older than three months. Notify the municipality within three days of moving (Articles 12 to 14 of the Law).
6. Register the honey facility. Apply to the Ministry before starting production (Form 1). Attach: the registration decision of the entrepreneur or legal person or, for individuals, a certificate of entry in the Register of Agricultural Holdings; proof of ownership or a lease of the premises; a description of production; proof of payment of the fee (ask the Ministry for the amount). You receive a decision and a registration number of the form SPH-3-0000. If you registered a facility before 2022, check that it is entered under the current rulebook, since the transition period has expired.
7. Prepare for inspection. The veterinary inspection carries out an official control no later than six months after entry. If conditions are not met, the inspector proposes revoking the decision.
8. Approval instead of registration is needed by a facility that fills and packs honey regardless of its origin, or does so as a service for others. Apply on Form 2 with a floor plan, a description of production, a self-control programme and proof of fee payment. A Ministry commission first grants a temporary approval and checks special conditions and HACCP before final entry. The facility receives a veterinary control number of the form BA-3-0000.
9. Label the honey. Labelling follows the food regulations, with the country of origin mandatory. For a blend from several countries, list the countries in the main field of view of the label, from the largest to the smallest share by mass, each with its percentage of the blend (a 5% tolerance per share is allowed, based on your traceability records). If there are more than four countries and the four largest shares make up more than 50% of the blend, percentages may be given for those four only, and the other countries are listed in descending order without percentages. On packs with less than 30 g of honey, country names may be replaced by two-letter codes (ISO 3166-1 alpha-2). These particulars are mandatory on the label.

Where to go

• Ministarstvo poljoprivrede, šumarstva i vodoprivrede Republike Srpske, Trg Republike Srpske 1, Banjaluka: Register entry, registration and approval of facilities.
• Municipal agriculture department (Trebinje, Bileća, Gacko, Ljubinje, Nevesinje, Berkovići): colony counts, the decision of approval for a mobile apiary and the grazing order.
• Veterinary inspection of the Republička uprava za inspekcijske poslove (Republic Inspectorate): official control of the facility.

Laws and sources

• Law amending the Law on Beekeeping (Službeni glasnik RS 17/23)
• Law on Beekeeping (Službeni glasnik RS 52/10), original text, Ministry of Agriculture, Forestry and Water Management
• Rulebook on the Register of Beekeepers and Apiaries (Službeni glasnik RS 19/24), entry in the official gazette e-register
• Rulebook on registration and approval of facilities for production and trade of food of animal origin (Službeni glasnik RS 92/22)
• Amendment of the Rulebook on quality of bee products (Službeni glasnik RS 7/25)