Serbia's new Chemicals Act: the Ministry of Environmental Protection's initial framework

Serbia is preparing a new Chemicals Act. During May 2026, the Ministry of Environmental Protection published the initial framework for drafting this law, opening a public debate on the directions in which the new regulation should develop.

The law currently in force was adopted in 2009 and has been amended several times, most recently in 2015. Since then, both the EU regulatory framework and the negotiating requirements towards Serbia as a candidate for membership have evolved considerably. In the initial framework, the new law is positioned as a response to those changes, and not just as a cosmetic revision of the existing text.

An important note before anything else: the initial framework is not a draft law. The document explicitly states that all proposals are “subject to amendments and additions” and represent starting points for discussion. The concrete legal solutions have yet to take shape.

Why a new law, and why now

The Chemicals Act is not a separate negotiating chapter in the EU accession process, but it has a direct impact on several chapters, in particular Chapter 1 (free movement of goods), Chapter 3 (right of establishment and freedom to provide services) and Chapters 27 and 28 (environment and consumer protection). The European Commission has defined specific benchmark requirements, and aligning the law is one of the preconditions for progress in the negotiations.

In addition, the National Programme for the Adoption of the EU Acquis for the period 2022-2025 envisaged the adoption of a new Chemicals Act in 2026.

What the initial framework envisages

The document identifies several key areas in which the existing law is not satisfactory.

Authorisation of substances of concern

Serbia does not yet have a functioning national authorisation system for SVHC substances, equivalent to the one that exists in the EU under REACH. The initial framework envisages introducing such a system, with a mandatory analysis of alternatives before a use is approved.

Status and obligations of chemical advisers

This is an area that directly touches Chapter 3. The new law should regulate more precisely the legal status of advisers, their responsibilities and the way they are engaged, as well as the conditions for cross-border provision of services and the recognition of professional qualifications from other countries. This is particularly relevant for Serbian experts who provide services to EU clients, and vice versa.

Abolition of NOH permits for trading in particularly hazardous chemicals

The permit system that has existed since 2009 has been recognized as an administrative barrier that is not in line with the principles of free movement of goods under Chapter 1.

Digitalization of the chemicals register

The initial framework envisages developing an integrated, interoperable system that would be technically compatible with ECHA’s systems and would enable active risk control, not just administrative record-keeping.

Register of intentionally added microplastics

Serbia would introduce an obligation to keep records of intentionally added microplastics for everyone who manufactures, imports or uses them, which is in line with the EU regulatory direction.

Green chemistry and substitution

The initial framework introduces the principle of substituting hazardous substances with safer alternatives as a legislative principle, and not just a recommendation.

The process that follows

The deadline for written comments from civil society organizations was May 27, 2026. Until May 19, a call was also open for organizations wishing to take part in the working group for drafting the law.

The draft law has yet to be prepared. After that comes the official public debate before it is sent into the parliamentary procedure.

I am attending the round table on the initial framework at the Chamber of Commerce and Industry of Serbia. Afterwards, I will publish my impressions and the key points from the discussion.

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This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.