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Construction and Demolition Waste Management Plans

Name: Izrada plana upravljanja otpadom od građenja i rušenja
Brand: Akhdar Consulting

If you are planning construction, demolition, or reconstruction of a building, you are legally required to have a Construction and Demolition Waste Management Plan. This document is a key part of the technical documentation and a requirement for obtaining a building permit and passing the technical inspection.

Our team prepares the plans quickly, accurately, and fully in accordance with the latest Regulation from 2023 and the current laws of the Republic of Serbia.

planovi upravljanja otpadom od gradjenja i rusenja Ahdar

What is a Construction and Demolition Waste Management Plan and why is it important?

The Construction and Demolition Waste Management Plan is a legally required document that defines how all types of waste generated during construction or demolition work will be managed.

The plan includes:

● Types and estimated quantities of waste,
● Methods of collection, separation, and disposal,
● Details about temporary storage and transportation,
● Identification of hazardous waste and its special treatment,
● Responsible persons and authorized operators.

The plan must be approved by the competent authority before work begins, and is then used as:

● Mandatory documentation for obtaining a building permit,
● Evidence during technical inspection for occupancy permit,
● The basis for the waste movement document as per regulations.

In accordance with the 2023 Regulation, the investor is obliged to:

● Prepare the plan,
● Submit it for approval,
● And implement it on the construction site.

The competent authority issues the approval decision within 30 days of receiving the complete documentation.

Without this document:

You cannot obtain a building permit,

Construction work may be suspended,

The inspection may impose fines and other measures.

The plan is not just a legal requirement – it is also a mechanism that ensures waste is managed safely, efficiently, and in accordance with environmental standards.

Who is legally required to have a waste management plan?

According to the Regulation on the manner and procedure of construction and demolition waste management (2023), every waste producer during construction and demolition must prepare and implement a Waste Management Plan.

This includes:

● The investor
● The contractor
● The building owner, if independently carrying out demolition

This obligation applies to all works on category B, V, and G structures, regardless of whether it involves construction, reconstruction, extension, adaptation, or demolition.

When is the plan required?

The waste management plan must be created and submitted:

● The waste management plan must be created and submitted:

● With the application for a demolition permit

● With the application for preparatory or temporary works

● And as part of the documentation for technical inspection / usage permit

Who grants approval?

The plan must receive an official approval before the start of works. Depending on who issues the permit, the approval is granted by:

● The Ministry of Environmental Protection (if MGI issues the construction permit)

● The Provincial Secretariat for Environmental Protection (if the competent authority is provincial)

● The local self-government – municipal environmental protection office (most common case)

The plan is submitted to the competent institution before submitting the permit application, and the deadline for issuing the approval decision is 30 days from the receipt of the complete documentation.

Without an approved plan:

● The permit cannot be issued

● Works cannot begin

● The investor is subject to inspection measures and fines

What does our professional preparation of the construction and demolition waste management plan include?

Our team handles the entire process and prepares a complete document that you can immediately use for the permit procedure.

Our service includes:

Project and works analysis

Review of submitted project documentation or basic project description

Support in identifying waste sources (e.g. demolition, excavation, dismantling)

Estimation of waste quantity and type

Classification into construction and hazardous waste

Estimation of quantities based on building type and works

Considering excavated material, packaging, construction dust, and residues

Defining waste disposal methods

Waste separation and storage method on site

Proposals for recycling, reuse, and landfilling

Instructions for hiring a licensed operator (or recommendation if you don’t have one)

Preparation of a legally compliant document

Plan prepared in accordance with the 2023 Regulation

Document formatted for acceptance by competent authorities (PDF and Word)

Contains all legally required elements — ready for inspection and technical review

Support during the approval process

Clear instructions on how and where to submit the plan

Advice regarding accompanying documents (e.g. waste report)

If needed — communication with the authority on your behalf

What you specifically receive:

● A complete and legally valid construction and demolition waste management plan

● Document ready for building and occupancy permits

● Formatted for acceptance by inspection authorities

● PDF and Word files delivered electronically

● Right to revisions and follow-up questions after delivery

What we need from you:

● Project location and type of work (e.g. construction, demolition, reconstruction)

● Technical documentation (if available)

● Investor or contractor data (if known)

● Location conditions or public authority permits/information

If you don’t have all the info — no problem.

Our team will guide you step by step and let you know exactly what we need to complete the plan without stress.

What measures are included in the construction and demolition waste management plan?

The waste management plan is not just a technical document for obtaining permits – it outlines specific measures that must be implemented on-site to manage waste safely, legally, and in an environmentally responsible manner.

Here are the key measures the plan must include:

Removal and separation of reusable materials before work begins

Before construction begins, materials that can be reused – such as bricks, tiles, metal, and carpentry – are separated from the site.

Separation of hazardous waste at the point of generation

If hazardous waste is generated during work (e.g., asbestos, contaminated soil, PCB compounds), it must be identified, labeled, stored separately, and handed over to an authorized operator.

Prevention of soil, water, and air pollution

The plan includes technical and organizational measures to prevent leakage, spillage, and uncontrolled dispersion of waste.

Defining a location for temporary waste storage

The site must have a clearly marked and protected area for temporary waste storage until it is handed over to an authorized carrier or operator.

Encouraging recycling and reuse of materials

The plan provides guidelines for separating fractions that can be recycled or reused, reducing the amount of landfill waste.

Record keeping and reporting obligations

The plan defines how waste is recorded (type, quantity, date), and the obligation to keep documents on waste handover to operators.

Implementing measures throughout the construction period

The measures in the plan are not a formality – they are implemented throughout the work and may be subject to inspection at any time.

All of these measures are a mandatory part of a legally valid plan and serve as the basis for inspection control. A plan that lacks clearly defined measures may be rejected or result in field penalties.

FAQ

The construction and demolition waste management plan is legally required for all works carried out on buildings classified as category B, V, and G, in accordance with the Regulation on the manner and procedure of managing construction and demolition waste (“Official Gazette of the RS”, nos. 93/2023 and 94/2023 – correction). This means it does not matter whether it is: ● new construction, ● reconstruction, ● adaptation, ● extension, ● or demolition of the building. If the building falls into one of the mentioned categories, the plan must exist and be approved by the competent authority before the start of works. Without this plan, a building permit cannot be obtained, and the investor risks fines or suspension of works.

Yes. The law does not differentiate between natural and legal persons regarding the obligation to prepare the plan. The key criterion is not the legal status of the investor, but the type and category of the building. If a private individual, for example: ● demolishes a house, ● builds a residential property, ● or adapts an existing building that falls into categories B, V, or G, – they are legally required to prepare a waste management plan, submit it for approval to the competent authority, and implement the measures defined in that plan on the construction site. In practice, many citizens only learn about this obligation when starting the process of obtaining a building permit, which can lead to delays if the plan is not prepared in time.

The waste management plan does not have a predefined validity period like a certificate or permit, but its importance is tied to the duration of the specific construction project for which it was made. This means: ● The plan is valid as long as the works on that building last, ● It must be implemented throughout the entire execution of the works, ● It is also used as part of the technical documentation during technical inspections and issuance of the occupancy permit. If a significant change occurs in the meantime – such as: ● change in the type of works, ● change of contractor, ● expansion of the scope of works, then a supplement or a new plan must be prepared and submitted for approval as well.

If the inspection during site supervision determines that: ● the waste management plan has not been prepared, ● or it is not implemented in practice (e.g., no waste separation, no containers, no records kept), this is considered a serious violation according to the Waste Management Law. Possible consequences include: ● fines for the investor and contractor, ● suspension of works until the plan is implemented, ● requirement for retroactive documentation and reports on waste disposal, ● and in severe cases – initiation of misdemeanor or even criminal proceedings, especially if environmental pollution occurred. Therefore, it is important not only to prepare the plan but also to actively apply it on site, keep records, and maintain all relevant documents.

The waste management plan must be prepared before submitting the building permit application and is submitted together with the documentation as part of the unified procedure. Without the plan approval decision, the competent authority will not consider the permit request. The same applies to: ● demolition permits, ● temporary work permits, ● and technical inspections (use permits). Therefore, timely preparation of the plan is crucial to avoid delays in the permitting process.

It depends on which authority issues the building permit, as the same level of government decides on plan approval. There are three possibilities: ● Local self-government (municipality or city) – in most cases. ● Provincial Secretariat for Environmental Protection – for provincial-level projects. ● Ministry of Environmental Protection – for projects subject to republic-level approval. Important: The plan is not submitted to the construction department, but to the environmental protection authority!

Yes. The waste management plan is not just a formal document – it must be implemented in practice on the construction site. This means: ● clearly labeled containers and waste storage areas must be provided, ● waste must be separated by type, ● hazardous waste must be specially treated and handed over to authorized operators, ● records must be kept (type, quantity, handover date), ● inspectors can visit at any time to review the plan and its implementation. Failure to implement may result in fines and work stoppages.

Yes. If during project execution there are significant changes affecting: ● waste quantity, ● types of works, ● contractor, ● container locations, ● waste flows, it is necessary to prepare an amendment (annex) to the plan and resubmit it for approval to the competent authority. Otherwise, the plan is considered non-compliant with the actual situation and may be grounds for inspection measures.

Penalties are prescribed by the Waste Management Law and can be serious: ● Legal entity: from 500,000 to 2,000,000 RSD ● Responsible person in company: from 25,000 to 150,000 RSD ● Individual (investor): from 20,000 to 50,000 RSD In addition to fines, inspectors may: ● halt works until the plan is prepared and implemented, ● request retroactive documentation, ● and in extreme cases – initiate environmental endangerment proceedings.

In most cases no, because works within an existing apartment (e.g., replacing tiles, kitchen, doors) do not require a plan if: ● they don't affect load-bearing structures, ● don't alter the building exterior, ● and aren't category B, V, or G works. But if renovation involves wall demolition, expansion, facade works, or requires a building permit – then a plan must be prepared. It's always best to consult before starting works to avoid interpretation errors.

No. A waste management plan is prepared per site and per construction activity. This means each of the following requires a separate plan: ● different locations (e.g., sites in two municipalities), ● different work types (e.g., construction + demolition), ● temporally separate activities. The reason is that each plan defines: ● specific waste quantities and types, ● concrete measures, ● exact container locations and waste flows, ● and authorized operators. Using one plan for multiple locations would violate the law and be automatically rejected.

Primary responsibility lies with the investor, as they submit the plan for approval and hold permits. However, in practice, the contractor manages daily site operations and must comply with the plan. Therefore, it's important that: ● the investor clearly defines waste management obligations in the contract, ● the contractor organizes separate collection, labeling, and storage on-site, ● both parties maintain records and cooperate during inspections. Legally, if irregularities occur, responsibility may be shared – the investor as client and the contractor as practical executor.

Yes. Under the Waste Management Law, only authorized operators (registered with the relevant ministry) may collect, transport, store, and treat certain waste types – especially hazardous waste like: ● asbestos, ● contaminated soil, ● PCB materials, ● and chemicals. For ordinary construction debris and soil, a local waste company may suffice if qualified. If waste is handed to an unregistered operator, it's considered a serious violation that may lead to fines and work stoppages.

Records are kept per the Regulation on Construction Waste Management („Official Gazette RS”, no. 81/2024), requiring: ● waste logs (manual or electronic), ● recording waste types (e.g., 17 01 01 – concrete, 17 05 03 – contaminated soil), ● quantities in tons or m³, ● collection/handover dates, ● operator's name and permit number, ● keeping copies of waste transfer documents (e.g., waybills). This documentation is used: ● during technical inspections, ● as proof of plan implementation, ● and may be requested during regulatory inspections.

If unplanned hazardous waste emerges (e.g., asbestos, polluted soil, old chemicals), you must: 1. Stop work in that zone, 2. Isolate and label the waste to prevent contact, 3. Notify authorities (e.g., environmental inspection), 4. Engage authorized operators for sampling, testing, and disposal. Then prepare a plan supplement describing the new waste and submit it for approval. Failure to properly handle hazardous waste may result in heavy fines, work stoppages, or even criminal liability.

Yes. Any significant change in works requires plan updates, including: ● changed work types (e.g., extension instead of renovation), ● increased scope (more waste), ● additional unplanned hazardous waste. In such cases, prepare a plan annex requiring re-approval before continuing works. Executing works under an invalid/outdated plan is legally considered plan non-compliance.

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