In early April 2024, the Environmental Protection Agency (EPA) issued a permit to the company "Eko modus" from Budva, the transit organizer, for the passage of 1.000 tons of non-hazardous metal waste through Montenegro.
The permit, which was published on the EPA website, states that the waste producer is the company “MZ Company” doo from Mostar, Bosnia and Herzegovina (BiH), while the waste importer is “Beani General Trading Co srl” from Libya.
However, the form, the document that accompanies this cargo through Montenegro, states a slightly different company name: “Beaini General Trading Co sarl”, and that the company is from Lebanon. The form is Center for Investigative Journalism of Montenegro (CIN-CG) obtained from the EPA, through the Freedom of Information Act (FOIA). The form is a document that the delivery organizer, in this case Budva-based “Eko Modus”, submits to the EPA, in order to obtain approval for transit through Montenegro.
The form states that the Lebanese company is an intermediary, but not the final recipient of the waste. The final importer in both documents does not specify the company, but only the country - Libya.
Libya is a country divided into two administrations, between which armed conflicts occasionally occur. Montenegro allows the transit of waste to that country without precise information about which administration is the final recipient, as well as which company takes over the load and how the waste will be treated after entering Libya.
"The goods were loaded onto a ship under the Tanzanian flag, while the port of Hereke in Turkey was declared as the place of unloading," the Customs Administration of Montenegro (UC) told CIN-CG.
However, none of the institutions and companies involved answered the question of which company ultimately took over the waste in Turkey and whether the goods ended up in Libya, as was supposed to be the case according to the documentation.
CIN-CG requested access to the export declaration signed at the Port of Bar from the Customs Administration, but they explained to UC that according to the Law on Customs Service, data from customs declarations and information on the value of goods constitute an official secret.
Analysis of waste transit permits in Montenegro for the last three years contains mostly precise data on the companies that are the final importers. The exception is this transit that originated from Bosnia and Herzegovina, which raises questions about the transparency and security of this cargo.
It would not be possible in the European Union
The EPA says they are unaware that the waste ended up in Turkey.
"According to the form, it was concluded that the waste in question ends up in Libya," he points out to CIN-CG. Danilo Veljic, independent consultant for the EPA's permitting and consent sector.
Veljić states that, as Montenegro is a transit country, the EPA does not have the authority to verify the final recipient of the waste in Libya, the procedures for processing and disposal of waste in the country of final destination. He says that the permit was issued under the then-current Law on Waste Management.
However, the situation is stricter in the EU. Since Libya is not a member of the Organisation for Economic Co-operation and Development (OECD), procedures for transboundary movements of waste to that country are subject to additional rules.
According to Regulation CE 1013/2006 and the new EU Regulation 2024/1157, it is not allowed to ship waste to non-OECD countries without a complete procedure of prior notification and written consent. This procedure is known as Prior Informed Consent (PIC).
The Ministry of Ecology, Sustainable Development and Northern Development (MERS) is responsible for harmonizing domestic legislation with European Union (EU) directives in the field of cross-border waste movement.
When asked when they intend to introduce EU directives, MERS responded that bylaws are being prepared that will fully transpose EU legislation in the field of transboundary movements of waste.
"MERS believes that the permit is legal and legitimate, because Montenegro is a transit country, and the shipment is accompanied by a form signed by the final recipient of the waste," the department said. Damjan Ćulafić for CIN-CG.
However, this form does not contain the signature of the final recipient, but only the signature of the director of the Budva-based company "Eko Modus". Sasa Vučetić.
MERS adds that in this specific case, it is the responsibility of the customs authorities to control whether the waste has left Montenegro for the country specified in the permit as the next destination.
Controls below the minimum: What happens to the transit of metal scrap
He is listed in local registers as the owner of a Bosnian company that is an exporter. Merhid ZlomušicaThe company's official website states that "MZ Company" is engaged in the purchase and recycling of secondary raw materials of metal origin.
According to the laws of Bosnia and Herzegovina, Zlomušić's company holds a license as an authorized operator for secondary raw materials of metallic origin. The Regulation on Waste Categories with Lists of Bosnia and Herzegovina defines the methods of classifying hazardous and unknown waste, and the obligation to classify waste is on the producer. In international trade, the role of the producer is taken over by the exporter - in this case "MZ Company".
As an authorized operator, the company has the right to export metal waste classified as non-hazardous under significantly simplified conditions, without the need for an export permit from the Federation of Bosnia and Herzegovina. The key condition for using this simplified regime, however, is the existence of evidence of the origin and nature of the material.
MZ Company refused to answer CIN-CG's numerous questions, including about the origin and properties of the metal. The form states that it is non-hazardous metal materials made of iron and steel.
The Ecological Inspectorate from Montenegro, responsible for controlling the type of waste, did not check this shipment.
In Montenegro, the Environmental Inspection is responsible for checking the type of waste.
Coordinator of the Ecological Inspection, Vesna Bigović explains to CIN-CG that control of cross-border waste movement is carried out exclusively at the request of border police or Customs Administration officials.
"The Environmental Inspection is not present at border crossings and does not carry out controls at the crossings themselves, but if necessary, and upon request from the border police or customs, it carries out activities in accordance with its jurisdiction," said Bigović.
From the moment the truck leaves Bosnia and Herzegovina for the Port of Bar, the shipment passes through two customs controls - at Vraćenovići and at the Port of Bar. The Customs Administration explained to CIN-CG that at the Vraćenovići border crossing, the shipment was carried out using transit documents.
"During entry into the area of the Port of Bar free zone, trucks with scrap iron were weighed on the scales of Luka Bar AD, for which certificates of weighing on the truck scales were issued. No irregularities were observed in the mass of the declared goods. The goods were in bulk. It was observed that the metals involved were scrap iron."
350 tons of metal entered Montenegro, and almost six times more left
Although the Budva-based company responsible for transit through our country requested permission to pass a thousand tons of waste, according to the records of the Customs Administration at the Vraćenovići border crossing, the total quantity was around 350 tons. This should be around 15 standard trucks. However, significantly more cargo was loaded from the Port of Bar, as much as two thousand tons.
"The goods were placed at the appropriate terminal - the open warehouse of Obala Volujice AD. Almost 2.000 tons of scrap iron were shipped by ship, which the free zone user placed in the free zone area," the Customs Administration told CIN-CG.
We did not receive an answer from the Customs Office when asked how the shipment increased from 350 tons in the documents to almost 2.000 tons. They did, however, explain that the Lebanese company "Beaini General Trading" is a user of the Port of Bar Free Zone.
The Port of Bar confirmed that the aforementioned Lebanese company concluded a contract in 2020 to carry out activities in the Free Zone, which relates to the storage, trade and export of iron scrap.
After an undefined period in an open warehouse, the bulk goods were loaded onto a ship flying the Tanzanian flag), UC explained.
An invoice in the amount of 573.763,20 euros was attached to the export declaration.
The Customs Administration responded that it was a ship. Star Light. This ship is registered in Tanzania by a Lebanese company. The country under whose flag the ship flies is responsible for the technical and safety control of the ship.
Ships flying the Tanzanian flag are on the blacklist of the Organization of European Maritime Authorities (Paris MoU) and are marked as high-risk. When they enter any port in the Paris MoU region (almost all European countries), they are automatically subject to increased controls (high priority inspection rate). They are often stopped for non-compliance. Here, however, this control was absent.
Hard-to-reach contacts and lack of transparency
During the course of the investigation, CIN-CG unsuccessfully tried to contact a user of the Free Zone Luka Bar from Lebanon. No contact email for the company was found online, and the form only listed a Montenegrin phone number, which is currently out of service, and an email address from which messages are returned.
Although according to the current Law on Free Zones, zone users do not have to have a registered company in Montenegro, the owner of the Lebanese company Nidal Beaini also founded the company “Beaini General Trading Co” in Podgorica, which deals with recycling sorted waste. This company does not have a contact email or an authorized representative on the “Business Network” website, and the only Montenegrin phone number is active and receives messages, but does not answer messages or calls. CIN-CG determined through the universal directory that this number is registered in the name of a person from Nikšić.
Beini founded the company in Podgorica on October 1, 2019, and the company has been blocked since 2022 and has a debt of 1.577 euros. There has been no activity recorded on "Business Network" in the last three years.
The application for a waste transit permit, signed by Saša Vučetić, director of the Budva-based company “Eko modus”, states: “I declare that to the best of my knowledge the above information is correct. I also confirm that the applicable obligations are set out in the form of a contract concluded with the recipient.”
The form lists the number as the “Eco Mode” contact Danijela Vučetić, an authorized representative, while the owner of the company Nebojsa BojanicCIN-CG contacted Vučetić, who provided two contact emails from the Lebanese company, but no answers to CIN-CG's questions from those emails were received.
Although “Eko Modus” is registered in the EPA's register of waste transporters for 2024, the company did not actually transit the shipment from BiH to the Port of Bar. The transport was carried out instead by another company - “Loyal doo”. That company did not respond to CIN-CG's questions either.
What are the risks?
In October 2025, in the Italian city of La Spezia, it was discovered that bales of multi-materials (plastics and metals) that were classified as “non-hazardous waste” contained remnants of explosive devices. The discovery was made only when the material arrived at a recycling plant and was opened for sorting and processing. It is just one of the latest cases in a country where there is much talk about problematic waste being smuggled.
It is known that in 2019, hazardous waste materials were sent from Montenegro to Ukraine and Spain, which were covered by non-hazardous waste documents.
"I want to highlight two important aspects. In the Mediterranean, it is necessary to coordinate the work of all institutions," he told CIN-CG. Claudia Salvestrini, Director of the “Polieco” consortium.
She also states that the case of waste exported from BiH, which we investigated, deserves answers to numerous open questions.
"This case confirms that there is seemingly strong control at the borders, yet much, if not too much, escapes."
The Italian consortium “Polieco” is responsible for the collection, monitoring and proper disposal of polyethylene-based plastic waste, especially that which is reused in industry. The consortium's goal is to prevent waste from ending up in illegal flows and to ensure environmental protection, through control of the entire cycle.
“Polieco” has insight into the system's data and problems - statistics, reports, examples of abuse, etc.
"Waste is something that gets out of control the most, especially during times of great international tensions and conflicts, which can cause great damage to the health of all of us and the environment," warns Director Salvestrini for CIN-CG.
She also emphasizes that it is important for them that institutions in Montenegro operate transparently, because everything happens right next to the Italian border, practically around the corner.
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