Today marks the final day of the public consultation on the  Integrated Pollution Prevention and Control (IPPC), a regulation that should serve as a key instrument for reducing industrial pollution and protecting public health.

Industrial facilities subject to integrated permit regimes represent the largest individual sources of pollution. In Serbia, more than 150 such facilities still operate without integrated permits, while permit issuance procedures often take years. This situation indicates that the system is not functioning properly and that institutions are failing to consistently enforce existing legislation.

The Draft Law does not offer solutions to these problems. A recently published analysis by the Platform for Social Development and Innovation (CORE) and the Friedrich Ebert Foundation shows a mismatch between the reform’s stated objectives and the proposed measures. Instead of addressing existing weaknesses, the Draft may in some areas even create new challenges in practice.

Particularly concerning is the fact that the Draft leaves room for deviations from Best Available Techniques (BAT standards), which are the core mechanism for reducing industrial pollution, without clearly defined criteria. This directly increases the risk of arbitrary application of the law.

The proposed solutions reduce public participation to a formality. For example, the Draft provides only a 15-day deadline for submitting comments on complex technical documentation, combined with outdated methods of public notification. This is also evident in the current public consultation process, which coincides with holidays and non-working days, further hindering public involvement. Such an approach limits meaningful participation of citizens, experts, and civil society organizations in decision-making processes that directly affect environmental quality and public health.

Problems are also evident in the area of supervision and enforcement. The proposed system does not ensure sufficiently clear and effective control mechanisms, while existing facilities remain in a more favorable position compared to new ones, even though they are often the largest polluters. Without consistent enforcement of the law, including prohibiting operations without integrated permits and ensuring adequate sanctions, it is not possible to expect a real reduction in pollution.

Without clear rules, effective oversight, and genuine public participation, the law risks remaining a dead letter, while the consequences of industrial pollution continue to affect citizens’ daily lives. Therefore, solutions are needed that will truly contribute to reducing industrial pollution, rather than merely achieving formal alignment with European standards.

Coalition 27 and the Platform for Social Development and Innovation call on civil society organizations, the expert community, media, and citizens to familiarize themselves with the key shortcomings of the Draft Law and to join in further monitoring of the adoption process, as well as in advocating for an open public discussion on effective solutions even after the formal consultation period ends.

The prepared comments and remarks on the Draft Law are available HERE.

This activity is part of the “Green Agenda Navigator” project supported by the European Union. The project is implemented by the Belgrade Open School in cooperation with six regional partners: the Aarhus Centre Association, Eco-Team organization, Eco-Z organization, the Center for Environmental Research and Information Eko-Svest, the Protection and Preservation of Natural Environment organization and CEE Bankwatch Network.