Dozens of reports from the Environmental Inspection, which the Center for Investigative Reporting of Montenegro (CIN-CG) has had access to, indicate serious irregularities, as healthcare institutions have not established a system for adequate disposal of medical waste, which could significantly endanger public health. The reports state that medical waste is often disposed of together with municipal waste, which is illegal and dangerous.
Although the Waste Management Law provides for the initiation of misdemeanor proceedings and fines ranging from 1.000 euros to 40.000 euros for mixing different types of hazardous waste, including hazardous and non-hazardous waste, during five years of inspections, not a single healthcare institution was held accountable, despite serious shortcomings.
Medical waste is potentially one of the most hazardous types of waste. Due to the high risk of spreading infections and communicable diseases, inadequate handling and improper disposal of medical waste can have serious and long-term consequences for public health and the environment.
Serious irregularities in medical waste management were found in several private institutions in Žabljak, Rožaje, Pljevlja, Nikšić and Bar.
"The waste generated is disposed of together with municipal waste," states the inspection report of a dental office in Žabljak from 2023.
The inspection then determined that the practice was disposing of all medical waste in the municipal waste stream, that it did not have a contract with an authorized waste disposal company, and that it did not keep records. The practice was founded in late 2019, which indicates that this practice had been going on for years.
An inspection of a dental practice in Pljevlja in 2023 found that a waste management system was not in place. "According to the client, the waste generated in the practice is not handed over to anyone, but is disposed of together with municipal waste," the minutes state.
The same document also states that they were not aware of the obligation to hand over medical waste to an authorized operator, even though the practice was founded in 2015.
Of the over 100 inspection reports from 2020 to 2024, which CIN-CG obtained through free access to information, shortcomings in establishing a system for adequate medical waste disposal were identified in almost all inspections, most often in the failure to keep records of the quantity and type of waste produced and in the lack of management plans. The most supervision, in these five years, was carried out in dental offices.
However, shortcomings in the disposal of medical waste have also been observed in public health institutions, despite the fact that inspections by the Environmental Inspectorate in the public sector are most often announced a day in advance.
The Environmental Inspection told CIN-CG that their supervision is primarily preventive in nature, which is why, instead of fines, they issue solutions to eliminate irregularities.
"In order to eliminate irregularities in medical waste management, decisions were issued to supervised entities to eliminate irregularities, which all supervised entities acted upon," they told CIN-CG.
They also confirmed that no misdemeanor fines were issued during 2025.
The Ministry of Health is unaware of these omissions and told CIN-CG that "if omissions are noted in the environmental inspection records, this is a serious violation of legal regulations."
"Such findings indicate weaknesses in law enforcement and the sanctioning system, which requires additional strengthening of inspection supervision, more precise procedures, and consistent application of punitive measures," they say in the Ministry, as if this were someone else's jurisdiction, not theirs.
Director of the Ecological Movement OZON Aleksandar Perovic warns that the absence of penalties and tolerating irregularities renders the control system meaningless and sends the message that laws do not have to be respected.
According to data from the World Health Organization (WHO), 20 to 25 percent of medical waste is hazardous medical waste, and the largest share of hazardous medical waste generated in state health institutions is infectious waste - 80 percent.
Monopoly weighs 10,5 million
The private company "Ekomedika" is the only one in Montenegro that has a concession for the disposal of infectious and sharp medical waste.
The Clinical Center of Montenegro (KCCG) and the Ministry of Health told CIN-CG that the fifteen-year contract between the Ministry of Health and "Ekomedika" expires in the middle of this year, and KCCG is seeking to take over the management of this type of waste.
The Ministry of Health told CIN-CG that they, together with the Ministry of Ecology, are considering the proposal of the KCCG to take over the job, emphasizing that taking over the disposal of this type of waste would be a huge savings for the state.
The KCCG told CIN-CG that, from 2016 to 2024, they alone handed over around 2,7 million kilograms of infectious waste to the company "Ekomedika".
This company was paid a little less than 10,5 million euros from public health institutions alone from 2013 to 2025, according to data provided to CIN-CG by the Health Insurance Fund of Montenegro.
In addition to public, all private healthcare institutions also hand over this type of waste to this company, but the company "Ekomedika" did not answer the question of how much money all healthcare institutions pay it annually for medical waste disposal services.
In 2011, “Ekomedika” signed a concession agreement with the Ministry of Health, i.e. the Government of Montenegro.
Under audit by the State Audit Institution (DRI) The effectiveness of medical waste management, made in March 2025, the different interpretations of the Ministry of Health and the company "Ekomedika" regarding the beginning and expiration of the concession agreement were questioned, which, as they say, may have certain legal consequences for the state if this issue is not resolved.
The DRI audit states that the position of the company "Ekomedika" at the time was that the deadline for the commencement of the Concession Agreement was January 27, 2014.
The company "Ekomedika", even after the CIN-CG journalist insisted, did not clearly answer the question of when they thought the concession would expire.
"Regarding the duration of the contract, it is defined as 15 years from the date of obtaining the usage permit and the decision for the facilities and equipment," the company said, without wanting to specify the date.
According to the concession agreement, “Ekomedika” has the right to claim damages in the event of a breach of contractual obligations.
"The concession agreement stipulates that ownership of the facilities, equipment and technology, upon the expiration of the contract, will be transferred to the grantor, i.e. the Government of Montenegro," the SAI audit states.
The company "Ekomedika" told CIN-CG "that through a partnership they resolved all challenges without legal disputes and that they would always exhaust all options before entering into a legal dispute, if necessary."
Even after several weeks, we have not received answers to numerous questions related to medical waste management from the Ministry of Ecology, Sustainable Development and Northern Development.
Infectious waste was mixed with municipal waste in the KCCG as well
Although infectious waste at KCCG is usually properly separated in the premises where it is generated and handed over to the company “Ekomedika”, sometimes improper disposal occurs. During a visit to KCCG in January of this year, a CIN-CG journalist found a yellow bag in the containers for municipal waste disposal, located next to the company “Ekomedika”, in which infectious waste is placed, which should not be disposed of together with municipal waste.
The company told CIN-CG that if there is a problem with inappropriate packaging and improper sorting, or the presence of pharmaceutical or chemical waste in infectious waste packaging, the waste is returned to the sender to correct the irregularities, or handed over to certified collectors of these types of waste.
"It happens sporadically that the tag falls off the bag, that the bag leaks or splits, that a needle ends up in the bag instead of in the sharps bin, but these are very rare and unintentional omissions that do not require additional actions and procedures and are possible in any healthcare institution," the company "Ekomedika" states.
While they claim that waste quantities are precisely measured and recorded in healthcare institutions before taking over, the KCCG says that infectious waste has so far been measured exclusively by "Ekomedika", which is why they have only now begun the construction of measuring stations with electronic scales within the Clinical Center.
"We have noticed that in the past period, the quantities of infectious waste were measured exclusively upon receipt by the contracted waste disposal concessionaire, which we consider unacceptable," the KCCG stated.
There is no reliable evidence, they do not follow the recommendations of the SAI
The SAI report notes that Montenegro does not have a national strategy for medical waste, nor a functional system of records and monitoring.
"The Ministry of Health keeps records in the form of Excel tables, exclusively for medical waste taken over by 'Ekomedika', with the data being kept collectively, without records for individual types of waste," Senator Dr. points out in the audit. Branislav Radulović.
The recently published report on the implementation of SAI recommendations points out that in almost a year, nothing has been done to improve the waste management system.
Of the 30 SAI recommendations, only five were implemented. The worst results were achieved by the hospitals in Bar and Nikšić. The hospital in Bar did not fulfill any of the recommendations. Both hospitals did not appoint responsible persons or adopt regulations on the basis of which they will manage medical waste. Only the Health Center in Podgorica fulfilled all SAI recommendations.
The Ministry of Health was assessed as very weak in implementing key recommendations. The SAI asked the Ministry to establish a functional monitoring system for medical waste management. The Ministry transferred responsibility to the department that runs it. Damjan Ćulafić and stated that there is no new medical waste management plan. The SAI points out that the National Waste Management Plan was adopted in October 2025, and that this cannot be an excuse.
The Ministry of Health announced to CIN-CG that the information system will be introduced by 2028, while the DRI indicates that so far "everything has remained at the level of ideas and future plans."
The auditor concluded that without these measures, the medical waste management system continues to function without reliable data on the quantity, movement, and method of waste disposal.
Perović from the NGO OZON warns that the lack of reliable data on the quantities of medical waste and unclear jurisdictions indicate a dysfunctional and chaotic system and leaves serious room for abuse and ecocrime. He adds that ignoring the findings of the DRI and other institutions is an insult to the public and confirms institutional disinterest.
Cartridge waste is not recorded separately
The inspection determined that health centers do not keep prescribed records or a waste management plan, and the community health service poses a particular problem.
According to the inspection report from 2022, infectious waste generated during home visits is not recorded separately, but is mixed with other medical waste at the health center, contrary to regulations.
The minutes state that there is no clear system for how this waste is returned, recorded and handed over to an authorized company, which is why outpatient waste is practically "drowning" into the overall waste of the health center, without the possibility of determining its origin, quantity and method of disposal.
The Local Health Office admits that there is a problem with the community health services, but that they will solve the problem, also by 2028.
"That is why the new medical waste management information system will also include community health services. Clear protocols for the disposal of waste generated in the home will be defined. Special containers and transport solutions will also be provided, and community health services will be software-connected to centralized waste records," the Ministry of Health said.
Private pharmacies will not accept medical waste from citizens
Three private pharmacies visited by CIN-CG journalists refused to accept expired medications, while the state-owned pharmacy "Montefarm" did.
Citizens should return all expired or unused medications to pharmacies, rather than disposing of them in municipal waste.
According to the Waste Management Law, from January 2025, all citizens should separately collect hazardous waste generated in households.
Pathoanatomical waste is addressed through the Law on Communal Services
The Ministry of Health states that problems in the management of pathological waste will be resolved with a new draft of the Law on Communal Activities.
"For the first time, pathoanatomical waste is clearly defined - body parts, amputees, tissues and organs removed during surgical procedures, placentas and other anatomical material that requires special disposal conditions," the Ministry said.
Mortal remains, they add, are specifically distinguished as the body, body parts of a deceased person, or ashes after cremation.
"The law stipulates that a city cemetery must have a special burial site
for pathoanatomical waste, thus providing a safe and permanent solution in accordance with health and environmental standards," the Ministry stated.
However, they, as well as other authorities, remain silent on the findings of our previously published research that some of this waste is exported as chemical waste.
We have noticed that in the past period, the quantities of infectious waste were measured exclusively upon receipt by the contracted waste disposal concessionaire, which we consider unacceptable, according to the KCCG.
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