An integrated environmental permit is an authorisation to operate an installation in which all conditions relating to environmental impact — emissions to air, discharges to water and soil, waste, noise, monitoring — sit in a single document. Whether you need an A or a B permit does not depend on the size of the company but on the activity and its capacity: the lists are in Annex 1 and Annex 2 of the Decree on integrated permits (Official Gazette of RM no. 89/2005). Annex 1 means an A permit from the Ministry, Annex 2 a B permit from the municipality.
What IPPC means
IPPC stands for integrated pollution prevention and control. Instead of separate permits for air, water and waste, the whole installation is examined at once — so that a problem in one medium is not solved by shifting it into another. A filter that cleans the dust but generates hazardous waste is not a solution. The framework is Chapter XII of the Environment Act (Articles 95–129, Official Gazette of RM no. 53/2005 as subsequently amended, most recently in Official Gazette of RNM no. 124/2025).
Who needs an A permit, who a B permit, and who only an elaborate
| Sector | A permit (Annex 1) | B permit (Annex 2) |
|---|---|---|
| Energy | Combustion above 50 MW; oil and gas refineries | Combustion 10–50 MW |
| Metals | Foundries above 20 t/day; smelting of non-ferrous metals above 4 t/day (lead, cadmium) or above 20 t/day; electrolytic tanks above 30 m³ | Foundries 2–20 t/day; smelting 0.2–4 or 2–20 t/day; tanks 5–30 m³ |
| Minerals | Clinker above 500; glass above 20; ceramics above 75 t/day; asphalt plants; asbestos | Clinker below 500; lime 10–50; glass 1–20; ceramics 5–75 t/day; concrete plants with silos above 50 m³; crushing of mineral raw materials |
| Chemicals | Basic organic and inorganic chemicals, fertilisers, biocides, pharmaceuticals, explosives | Cutting polyurethane foam with a heated wire |
| Waste | Hazardous waste above 10 t/day; incineration of municipal waste above 3 t/h; non-hazardous above 50 t/day; landfills above 10 t/day or 25,000 t | The same installations not falling within Annex 1 |
| Food and livestock | Slaughterhouses above 50; animal raw materials above 75; vegetable above 300; milk above 200 t/day; above 40,000 poultry; above 2,000 pigs or 750 sows | Slaughterhouses 5–50; animal 5–75; vegetable 30–300; milk 20–200 t/day; poultry 5,000–40,000; pigs 100–2,000; sows 50–750 |
| Other activities | Paper above 20; textiles above 10; leather above 12 t/day; solvents above 150 kg/h or 200 t/year | Paper 5–20; textiles 1–10; leather 0.5–12 t/day; solvents 10–150 kg/h |
Two rules resolve most borderline cases. First, the thresholds relate to design production capacity, not to actual annual output. Second — most often overlooked — where one operator carries out several activities from the same industrial sector at the same location, the capacities are added together (Article 4 of the Decree): two lines of 12 t/day each are not two B installations but 24 t/day.
If the activity appears in neither annex, you do not need a permit, but you do have an obligation: Article 24 of the Act applies and an environmental protection elaborate is prepared, which neither replaces the permit nor is replaced by it.
Who issues the permit
The A permit is issued by the Ministry of Environment and Physical Planning (Articles 95(2) and 96).
The B permit is issued by the mayor of the municipality or of the City of Skopje. The sole exception: an installation in a protected area goes to the Ministry (Article 123(1)). The municipality must have designated at least one person with higher education in the natural or technical sciences; where an installation extends across two municipalities, the application goes to the one holding the larger part.
The procedure step by step
Application. The form is prescribed by the Rulebook on the procedure for obtaining an A integrated environmental permit (Official Gazette of RM nos. 4/2006, 116/2014 and 31/2016), or by the Rulebook on the B integrated environmental permit (Official Gazette of RM no. 112/2014). It contains details of the operator and the installation, raw materials and energy, waste, emissions to air, water and soil, noise, monitoring points, an improvement programme, accident prevention, remediation and a statement of accuracy.
Completeness and publication. Within 30 days the authority determines by conclusion what must be added to the application; the deadline for supplementation is not shorter than 15 days, and failure to act means the application is rejected (Article 97). A complete application goes to the Ministry of Health, the other competent authorities and the municipality (Article 98) and is published in a daily newspaper and online within seven days, at the applicant's expense (Article 99).
Public review. The public has 30 days to submit opinions (Article 103), and the mayor the same — silence means no comments (Article 100). At the request of the public concerned, the developer organises a public hearing. The draft permit then goes to the operator and to the public, each with 14 days for comments (Article 107).
Site visit and decision. Before the decision, the installation is inspected; for B permits this is done by the State Inspectorate where the installation is in a protected area, otherwise by the authorised municipal inspector. The deadline for deciding is 60 days — for a B permit from receipt of a complete application (Article 126), for an A permit from the expiry of the deadline for opinions, extendable by up to 30 days in complex cases (Article 105).
Where an impact assessment is mandatory, the permit is issued only after consent to the EIA study (Articles 108 and 128). A permit to operate the installation is not issued without it.
Best available techniques (BAT)
BAT are the most effective and advanced stage in the development of operating methods, practically applicable to preventing or — where that is not possible — reducing emissions (Article 5, point 39). "Available" means available in the sector under economically and technically acceptable conditions, not theoretically possible.
This is not a declaration. An A permit is based on BAT, and emission limit values and the other conditions are set on that basis (Article 107); if the proposed techniques do not accord with BAT for the sector, the application is refused (Article 106). What constitutes BAT for a sector is determined by the Scientific and Technical Commission at the Ministry, through national reference documents (Article 104). Where no national document exists, the European Union reference documents (BREFs) are taken into account.
Obligations after the permit is issued
- A responsible person for implementing the permit conditions (Article 111).
- Monitoring at the points and with the frequency set in the permit; emission measurements from stationary sources are carried out by laboratories accredited to MKS EN ISO/IEC 17025 (Official Gazette of RM no. 11/2012, amended in Official Gazette of RNM no. 176/2019) — see air emissions and ambient air and measurements and testing.
- Reporting: regularly on monitoring results; immediately on any malfunction, accident or breakdown; on every change in operations and in authorised persons (Article 111). The permit contains a separate "regular reports" section — in practice, an annual report on the operation of the installation.
- Emissions log — records by source and parameter, maintained continuously during operation. It is the basis from which the annual report is compiled and is as a rule the first document an inspector asks for. Its form and the manner of keeping it are prescribed by a dedicated rulebook (Official Gazette of RM no. 79/2011).
- Retention of documentation for the duration of validity and for five years after expiry (Article 110), plus assistance to the inspector (Article 112).
- Fees on submission, amendment and transfer, annually for holding the permit and for regular oversight: for an A permit MKD 1,000–9,000, for a B permit MKD 300–3,000 (Articles 121 and 129).
The conditions from waste management permits and from discharge permits are incorporated into the integrated permit.
Amendment, renewal and withdrawal
The competent authority must review the conditions every seven years and amend them if necessary (Article 115 for A, Article 126 for B). An application to renew an A permit is submitted at the latest one year before the expiry of that period.
Amendment ex officio takes place where BAT develops so as to permit a significant reduction in emissions, where safety requires a different technology, where pollution has increased, on changes in the regulations, or after a general environmental audit. Amendment at the operator's request is initiated by notifying the planned change; if it is significant, a procedure for a new permit follows. The deadline for amendment is 90 days (Article 117) and for transfer 60 days (Article 118).
A permit is withdrawn where the operator has breached the conditions more than three times under final inspectorate decisions, has made changes without a permit, or does not carry out the activity within the scope of the permit (Article 119); for a B permit an unpaid fee is also a ground, with a maximum of 30 days to remedy the cause.
What you risk by operating without a permit
Operating without an integrated environmental permit is a category II offence (Article 212-е(1), point 15). Following the amendments in Official Gazette of RNM no. 89/2022 the fines are:
| Size of trader | Legal entity | Responsible person |
|---|---|---|
| Micro | EUR 13,000–14,000 | EUR 700 |
| Small | EUR 25,000–28,000 | EUR 1,500 |
| Medium | EUR 76,000–84,000 | EUR 4,000 |
| Large | EUR 126,000–140,000 | EUR 7,000 |
Amounts are in denar equivalent, and the competent body is the court. The same article lists monitoring not carried out as a separate point — a properly issued permit without monitoring leads to the same category of offence.
A permit, B permit or elaborate — a comparison
| A integrated permit | B integrated permit | Elaborate | |
|---|---|---|---|
| Who issues it | Ministry of Environment | Mayor of the municipality/City of Skopje; the Ministry if in a protected area | Municipality/City of Skopje or the body for specialist environmental activities |
| For whom | Installations in Annex 1 of Decree 89/2005 | Installations in Annex 2 | Activities outside both annexes, covered by the elaborate decrees |
| Legal basis | Articles 95–121 of the Environment Act | Articles 122–129 of the Act | Article 24 of the Act |
| Procedure | Application, consultations, publication, 30 days public review, draft permit, site visit, decision | Application, site visit, inspector's review, decision | Preparation, submission through the authority approving the activity, decision |
| Decision deadline | 60 days from expiry of the deadline for opinions (+30 in complex cases) | 60 days from a complete application | Per the approval procedure |
| Conditions | Based on BAT | Emission limit values and monitoring | Protection programme |
| Review | Every 7 years | Every 7 years | No prescribed cycle |
What the new act changes from 2027
The new Industrial Emissions Control Act has been adopted (Official Gazette of RNM no. 193/2025), aligned with Directive 2010/75/EU. It entered into force in September 2025 but applies from September 2027. On the day it takes effect, Articles 95–129 and 134–144 of the Environment Act cease to apply — the entire framework described above. Until then the regime set out here applies, but it is worth designing conditions so that they hold up after the transition.
How we can help
RI-Opusproekt has delivered 59 integrated environmental permits — A and B, for installations in energy, metallurgy, minerals, food processing and waste. We first establish the category under the two annexes and the capacity-aggregation rule, then compile the application, and carry out the measurements with our own instruments. See the integrated environmental permits service or request a quote with your activity code and design capacity — we establish in advance whether you need a permit or an elaborate.
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.
