Coalition 27, a group of eight civil society organizations, presented its new, twelfth in a row in November the report from the shadows, which analyzes Serbia's progress in the area environmental protection and climate change.
But is there progress at all if this year's edition is symbolically titled "System Error"?
Instead of progress, the release points to serious procedural flaws, weak implementation and systemic failures by the authorities that have led to the stagnation of key reforms and the devastating state of the environment.
One of the examples of system errors is reflected in the attitude towards the air. According to Coalition 27, the new Law on Air Protection will apparently not eliminate the essential causes of pollution. It remains a major health threat that we face every day, and an additional problem is that a third of the population of Serbia still has no real insight into the quality of the air they breathe.
Generally speaking, despite the adoption of certain regulations and strategic documents, Serbia is still progressing slowly and insufficiently, warn the Coalition 27.
Delays in the drafting and implementation of regulations, weak supervision, non-sanctioning of irregularities and lack of political will to solve problems in a systemic way, the same patterns are repeated in most areas from Chapter 27 on the road to accession to the European Union (EU), and this has been for years. We can see this even if we only glance at the headlines of previous shadow reports, e.g. "Report on (lack of) progress" (2018), "One step forward, two steps back" (2022), "The years go by, we stand still" (2024).
Given this chronology of failure, the System Failure Report doesn't offer much optimism either, but it does map precisely where the key bottlenecks are occurring, focusing on the period from May 2024 to May 2025.
Now traditionally, the authors also provide recommendations for each individual area of Chapter 27: from horizontal legislation to water quality and nature protection to climate change.
What does the publication say?
Although air pollution is perhaps the most talked about issue, it is far from being the only challenge facing Serbia when it comes to environmental protection. We also witness that, as a consequence of a poorly set up system, irresponsible waste management is increasingly paying off.
The number of landfill fires is increasing, and with them pollution and health risks. The sanitary landfill "Duboko" in Užice burned for three weeks in May of last year, and its closure shows how deep a systemic error can be: millions of euros of public money were lost, and citizens were left without a solution for waste disposal, notes the Coalition on 27.
When it comes to the water sector, progress is hindered by delays in drafting documents, a low level of public involvement and weak implementation of regulations. Many plans remain at the draft level, and inefficient implementation in practice further distances Serbia from European standards.
We remain far from European standards when it comes to the total area of protected areas: it has slightly increased compared to the previous report and protected areas now occupy 9,34 percent of the territory of Serbia. The increase of 0,69% is higher compared to the previous year when it was 0,5%. However, this data should not be taken for granted: progress is still insufficient in relation to the needs of biodiversity conservation, and the pressures on nature continue and grow.
The state of forestry is almost unchanged, marked by illegal logging, inadequate management of private forests and weak control capacities. Although the drafting of the new law on placing wood on the market has begun, a large part of the actors (natural persons) remains outside the process. As stated, afforestation is showing a slight increase, but damage from storms and windbreaks is still significant.
One of the most complex areas of environmental protection is still industrial pollution. According to the EU report, Serbia's compliance with its acquis remains only partial.
It is necessary to accelerate the development of a new law on integrated prevention and control of environmental pollution, as well as to strengthen the application of the best available technologies (BAT), write from Coalition 27. This need for systemic action is equally expressed in the field of climate policy, which is directly related to the industrial and energy transition.
Kruševac and Šabac for the first time on the list of cities with excessively polluted air
Coalition 27 states that the state report on the state of air quality was published six months later than the legally prescribed deadline.
According to this report, the air is excessively polluted in 13 cities and eight agglomerations, including Belgrade, Novi Sad, Niš, Bor, Subotica and Sombor. Kruševac and Šabac were included in the list of cities with excessively polluted air for the first time.
It is of additional concern that even eight cities with excessively polluted air have neither adopted an Air Quality Plan nor a Short-Term Action Plan.
Serbia still does not have a functional climate policy system despite the existence of a legal framework. Implementation is seriously delayed due to the lack of key by-laws, and the Action Plan for the Low Carbon Development Strategy has not been adopted. An additional problem is that even the draft Environmental Protection Strategy does not set ambitious decarbonization goals. This stagnation directly affects the energy goals, and this can be seen in the data: the share of renewable sources in the gross final energy consumption fell from 26,3 percent (2020) to 25,43 percent (2023), further moving Serbia away from the goal of 33,6 percent by the end of the decade.
In the past year, the authors of the "System error" report also identified a serious problem of interweaving of responsibilities between sanitary and environmental inspection. While they mutually declare themselves incompetent, toxic products intended for widespread use are still on the market, which directly endangers the health of citizens, especially children. Information on the implementation of international conventions in this area is not publicly available, and administrative capacities remain insufficient.
The findings of the new shadow report show that Serbia still does not have an effective environmental protection system.
Without the responsibility of institutions, strengthening supervision, compliance with the law and the involvement of all actors, from local communities to industry, no policy will have real effects, they conclude from Coalition 27 and call on the institutions to urgently improve the management of environmental sectors, ensure consistent implementation of regulations and provide citizens with the right to a healthy environment.
