A new dedicated act removes the entire subject of integrated environmental permits from the Environment Act. The Industrial Emissions Control Act was published in Official Gazette of RNM no. 193 of 18 September 2025, entered into force on the eighth day after publication, and begins to apply two years later — from 26 September 2027. Those two years are not a pause: they are when the secondary legislation is adopted and operators build the documentation they will need on day one.
What the new act is and exactly when it applies
The Act has 119 articles and aligns Macedonian law with Directive 2010/75/EU on industrial emissions. The aim is for all emissions from an installation — to air, water and soil, along with waste, noise and energy efficiency — to be considered together, in a single instrument.
The date follows from Article 119: the Act enters into force on the eighth day after publication (published 18 September 2025, therefore in force from 26 September 2025), and begins to apply two years after entry into force — 26 September 2027.
The second important date is in Article 117: all secondary legislation must be adopted within that same two-year period, including the government decrees determining the activities for A and B installations.
What ceases to apply and what remains
Article 118 is express: on the day application begins, Articles 95–129 and 134–144 of the Environment Act cease to apply, as do Articles 87–91 of the Waste Management Act. In practice:
- Chapter XII of the Environment Act (Arts. 95–129) — the entire regime of A and B integrated environmental permits — moves into the new Act.
- Chapter XIV (Arts. 134–144) — compliance permits with an operational plan — is abolished in its entirety. The new Act recognises no such instrument.
- Arts. 87–91 of the Waste Management Act — the rules on burning and incineration of waste — are replaced by a dedicated Chapter VI on incineration and co-incineration.
- Chapter XIII of the Environment Act (Art. 130 — general environmental audit on cessation of activities and on transfer of an A permit) is not on the repeal list and remains in force.
What the Act does not regulate is the fate of permits already issued. The transitional and final provisions contain only three articles — 117, 118 and 119 — and none of them says whether existing A and B permits and compliance permits continue to be valid, until when, or by what deadline a new application must be filed.
This is not a minor point. An operator holding a valid A permit has no statutory answer to the question of what happens to it on 26 September 2027. Most likely the question will be settled later — by secondary legislation under Article 117 or by an amendment before application begins. Until then the only sensible course is not to wait: compare the conditions in the existing permit against the requirements of the new Act and close the gaps gradually, rather than all at once in 2027.
The same applies to holders of compliance permits. Since the new Act does not recognise that instrument at all, their position after 2027 is the most uncertain of all — for them preparation should start earliest.
Who the Act covers
Under Articles 3 and 16, the Act covers six groups:
- industrial installations requiring an A integrated environmental permit;
- large combustion plants — with a rated thermal input equal to or above 50 MW, whatever the fuel (Art. 55);
- plants for incineration and co-incineration of waste (Art. 66);
- installations producing titanium dioxide (Art. 71);
- installations using organic solvents (Art. 76) — these do not receive a permit but a registration decision;
- installations with smaller-scale activities — a B integrated environmental permit (Art. 89).
The activities and thresholds are determined by the Government (Art. 16(6) and Art. 89(2)). The new decree has not yet been adopted — the deadline for all secondary legislation is 26 September 2027 (Art. 117). Until it is adopted, the thresholds in the Decree determining installation activities requiring an integrated environmental permit (Official Gazette of RM no. 89/2005) remain the reference point — cement plants, foundries, galvanising, asphalt and concrete plants, slaughterhouses, landfills, textile finishing, farms. Given that the Act transposes Directive 2010/75/EU, it is realistic that the thresholds will move closer to those in the Directive — so borderline cases are worth checking against the Directive rather than only against the old decree.
The Act expressly does not apply to research and development activities or to testing new products and processes (Art. 4).
Current and new regime — what changes
| Issue | Current regime (Environment Act) | New regime (new Act) |
|---|---|---|
| Legal basis | Chapter XII (Arts. 95–129) and Chapter XIV (Arts. 134–144) | Official Gazette of RNM no. 193/2025 |
| Instruments | A permit, B permit and compliance permit with an operational plan | A permit, B permit and a registration decision for organic solvents; no compliance permit |
| Best available techniques | A condition on issue | The European IPPC Bureau conclusions are adopted by ministerial decision and published in a List; four-year compliance period (Art. 44) |
| Combustion, incineration, TiO₂, solvents | Separate regulations and the Waste Act | Dedicated chapters in the same Act; requirements enter the A permit (Art. 25(2)) |
| Soil and groundwater | No baseline report obligation | Baseline Report (Art. 52); monitoring at least every 5 years (groundwater) and every 10 years (soil) (Art. 22(3)) |
| Register | Permit registers | A national register, updated weekly (Art. 19) |
| Review of conditions | Every 7 years (Art. 115(6) and Art. 126(8)) | Every 7 years; A permits are also renewed every 7 years (Art. 32(10), Art. 46(13), Art. 98(12)) |
Key new obligations for the operator
BAT-based limit values. Emissions to air, water and soil and noise levels must be brought within the limits set in the regulations, in the best available techniques conclusions or in the permit itself (Art. 21), and the values in the permit must not exceed the levels associated with BAT (Art. 39(4)). Lower requirements are possible only by way of exception — where an assessment shows disproportionately high costs due to the location or technical characteristics (Art. 40).
Monitoring and reporting. The methodology and frequency are set in the permit (Art. 22, Art. 38(5)), results are submitted at least once a year, and the annual environmental report is filed by 31 March for the preceding calendar year. For large combustion plants with an input of 100 MW or more, monitoring of SO₂, nitrogen oxides, particulates and carbon monoxide is continuous (Art. 61).
Baseline Report on soil and groundwater. Where the installation uses, produces or releases hazardous substances and there is a possibility of soil and groundwater contamination, the operator prepares a Baseline Report and submits it with the application (Art. 52); for existing installations — before amendment or transfer of the permit. It becomes the yardstick: on closure the position is compared against it and the operator takes measures to restore that state (Art. 53). The documentation is retained for at least 10 years (Art. 23(1)).
Public participation. A complete application is published in two daily newspapers and online, at the applicant's expense (Art. 31). The public has 30 days to submit opinions, and at the request of the public concerned the operator must itself organise a public hearing (Art. 35(5)). On the draft permit the operator has 30 days for comments and the public 15 days (Art. 38).
Accidents. In the event of an accident the operator notifies immediately and takes intervention measures (Art. 17). On a breach of the permit conditions — it notifies immediately, takes measures and reports on what was done (Art. 18(2)).
Deadlines already running
| Deadline | What it means | Basis |
|---|---|---|
| 26 September 2025 | The Act enters into force (eighth day after publication) | Art. 119 |
| by 26 September 2027 | All secondary legislation must be adopted | Art. 117 |
| 26 September 2027 | Application begins; Arts. 95–129 and 134–144 of the Environment Act and Arts. 87–91 of the Waste Act cease to apply | Arts. 118 and 119 |
| 4 years from entry into force of the BAT List | Alignment of operations and of the permit conditions | Art. 44(7) |
| 1–4 years | Alignment following amendment of a B permit ex officio | Art. 99 |
| Every 7 years | Renewal of the A permit and review of conditions for A and B | Art. 32(10), Art. 46(13), Art. 98(12) |
| By 31 March each year | Annual environmental report | Art. 23(4), Art. 103(2) |
| 90 days before operations begin | Registration for installations using organic solvents | Art. 77(3) |
| 30 days before ceasing operations | Notification and a draft plan of remediation measures | Art. 51(1) |
The decision on an A permit is issued within no more than 180 days of a complete application, extendable to at most one year from submission (Art. 36); for B permits the deadline is 60 days (Art. 98).
How to prepare — what you can do now
The two years are enough if they are used:
- Establish which category you fall into. Check your capacities against the thresholds. Where one operator carries out several activities from the same sector at the same location, the capacities are added together — which often means moving from category B to category A.
- Review your existing permit. If you operate under a compliance permit, that instrument disappears; unfulfilled measures from the operational plan are an input to the future application. More: A and B integrated environmental permits.
- Take a baseline survey of soil and groundwater. If you work with hazardous substances, the Baseline Report will be mandatory, and on closure that state is the reference point.
- Check how your emissions are measured — air emissions and ambient air and the other measurements and testing. The frequency will be a permit condition, not an assumption.
- Find the BAT conclusions for your sector. The four-year period runs from publication of the List, not from the moment you notice it.
- Put 10 years of documentation in order and check the earlier instruments: the application is submitted on the basis of a decision approving an EIA study or an approved environmental elaborate (Art. 20).
What you risk
Offences are divided into three categories. Fines for a legal entity, in euro in denar equivalent:
| Category | Example | Micro | Small | Medium | Large |
|---|---|---|---|---|---|
| I (Art. 111) | Documentation not retained; no Baseline Report | 6,000–7,000 | 13,000–14,000 | 37,000–41,000 | 62,000–69,000 |
| II (Art. 112) | Failure to notify an accident; no monitoring | 9,000–10,000 | 18,000–20,000 | 53,000–59,000 | 88,000–98,000 |
| III (Art. 113) | Emission limit values exceeded | 13,000–14,000 | 25,000–28,000 | 76,000–84,000 | 126,000–140,000 |
A ban on carrying on the activity for three months to two years may additionally be imposed, and the inspector may restrict or prohibit the operation of the installation by decision (Art. 108).
How we can help
Opusproekt works on integrated environmental permits — the application, the documentation and the accompanying elaborates — and carries out measurements with its own instruments. Send us the details of your capacities and existing permit, then request a quote: we will prepare an overview of your obligations and a sequence of steps through to 2027.
This article is informational and does not replace professional advice. Regulations change — last updated: August 2026.
This article is informational and does not replace professional advice.
