On December 15th, the Croatian Parliament passed, under an urgent procedure, the Law on the Construction of a Center for the Disposal of Radioactive Waste on Trgovska Gora, right along the border with Bosnia and Herzegovina (BiH). Earlier assessments by critics of that decision stated that this disposal site, located less than one kilometer from the border with BiH, would endanger the health of at least 250.000 people in 13 municipalities in the Una River basin, but authorities in Croatia denied any danger to public health.
A special law (lex specialis) defines the area for the placement of the facility at the site of the former military storage complex Cerkezovac (Trgovska Gora), where radioactive waste from the Krsko Nuclear Power Plant and institutional radioactive waste from Croatia from hospitals and industry will be disposed of, which is currently temporarily stored at various locations, in Zagreb at two institutes, as well as within the premises of numerous hospitals. BiH media has previously reported that all of this is being done without a strategic environmental impact assessment at the level of Croatia’s national spatial development plan and without the involvement of the public and the local population from BiH in the decision-making process.
The intention to store radioactive waste at this location dates back to 1997, which means that the authorities in BiH had more than enough time to become more actively involved. Ten years ago, in 2015, municipalities from the Una River basin signed a joint letter to halt the activities, after which, in 2016, the Parliamentary Assembly of BiH (PABiH) adopted a Resolution on rejecting the construction of a storage and disposal facility for radioactive waste on Trgovska Gora. That same year, the National Assembly of Republika Srpska (NARS) adopted a Resolution opposing activities related to the construction of a low- and intermediate-level radioactive waste disposal facility in the municipality of Dvor.
During that period and in the years that followed, protests were organized in potentially affected municipalities. In Croatia, meanwhile, preparations continued; in 2020, the Fund for Financing the Decommissioning and Disposal of Radioactive Waste and Spent Nuclear Fuel of the Krsko Nuclear Power Plant took over from the Croatian Ministry of Environmental Protection and Energy the use of the site of the former military warehouse Cerkezovac, in the municipality of Dvor.
In 2021, an Expert and Legal Team for Trgovska Gora was formed in BiH, which presented the position that it is dangerous to store radioactive waste on the border between Croatia and BiH. The Assembly of Novi Grad requested an urgent reaction from the Presidency and the Council of Ministers of BiH in order to prevent Croatia from implementing its plans.
In 2025, the Fund for Financing the Decommissioning and Disposal of Radioactive Waste and Spent Nuclear Fuel of the Krsko Nuclear Power Plant announced that the demolition of eight storage buildings at the site of the former JNA barracks Cerkezovac on Trgovska Gora had been completed, in order to free up space for the construction of a radioactive waste storage facility.
The Federal Ministry of Environment and Tourism did not receive any official notification via the Ministry of Foreign Affairs of BiH from the institutions of the Republic of Croatia regarding the demolition of the mentioned facilities, nor does it have any official information on the status, that is, the readiness of the Environmental Impact Study, as well as on the manner in which it will be made available for review by the BiH public, the Ministry of Environment and Tourism of the Federation of BiH (FBiH) reacted.
According to the opinion of the Legal Team for Trgovska Gora, as presented in the Strategy for the Legal Protection of the Interests of BiH in connection with issues of radioactive waste and spent nuclear fuel disposal at the Trgovska Gora site, formal consultations that essentially do not take into account the objections of the opposing side constitute a violation of the obligations of the ESPOO Convention.
“With regret, we note that Croatia refuses to include experts and institutions from BiH in the research of the Cerkezovac site and to jointly, under a unified project, investigate the wider area of the site, including the territory of BiH, that is, the area potentially affected by the project on the territory of both states. Existing geological knowledge of the terrain of the wider Trgovska Gora area and the Cerkezovac site shows that this is terrain with a very complex geological structure and that, according to the opinion of the Expert Team, detailed geological and hydrogeological research is required on both sides of the state border and the Una River in order to assess the suitability of the Cerkezovac site,” the Ministry stated.
The position of the experts is that the Environmental Impact Study cannot be carried out without joint work and research by experts from both sides, which must take place under secured field conditions, free from any danger that may arise due to the presence of landmines and unexploded ordnance.
The Minister of Foreign Trade and Economic Relations of BiH, Stasa Kosarac, sent an open letter last week to members of the Croatian Parliament. He warned that the proposed Law on the Construction of the Center for the Disposal of Radioactive Waste is an act that marks an unlawful entry into the final phase of a political project in the form of a planned radioactive waste storage facility on Trgovska Gora, and called on members of parliament to consider, before voting, the serious consequences that the realization of this project could have on public health, the environment, and overall security both on the territory of the Republic of Croatia and on the territory of BiH. At the same time, the ministry headed by Stasa Kosarac had funds at its disposal to protect the interests of BiH in connection with the planned disposal of radioactive waste at the Trgovska Gora site in Croatia. In 2023 and 2024, the Ministry spent only a small part of that amount.
The audit showed that the Ministry of Foreign Trade and Economic Relations of BiH in 2024 had at its disposal 500.000 BAM in budgetary funds under the Special Purpose Program item, with the aim of financing the activities of the Legal and Expert Team for the protection of the interests of BiH in connection with the planned disposal of radioactive waste at the Trgovska Gora site in Croatia. The audit report showed that by December 31st, only slightly more than 57.000 BAM had been used, raising issues regarding payment procedures and the engagement of international legal experts.
In cooperation with the BiH Attorney’s Office, the Ministry issued a public call for the selection of an international law firm for legal advisory services only in mid-2024. In September 2024, the Council of Ministers of BiH approved, by a special decision, more than 700.000 BAM, which will be allocated over the next three years. A contract was concluded with the law firm Laborde Law from Paris with an agreed fee of 200 euros per hour of engagement, with the total fee not exceeding the amount of 360.000 euros.
In the budget for 2023, the Ministry was approved funds in the amount of 500.000 BAM for the Special Purpose Program Trgovska Gora. However, the Ministry carried out a restructuring of expenditures, reducing the funds by 180.000 BAM, so that the final available funds amounted to 320.000 BAM. The funds were intended to finance the costs of the Legal and Expert Team. In 2023, slightly less than 200.000 BAM was spent for the payment of one-time monetary compensation for the work of members of the Legal and Expert Team. By one of the decisions determining the amount of individual one-time compensation for members of the expert team, these were set in amounts ranging from two to 10 thousand BAM per person:
“As justification for the decision, it is stated that the members of the expert team are specialists in the field of radioactive waste management, geological, seismological, hydrogeological and other types of research, and that they carried these out with the aim of preparing comprehensive analyses, drafting proposals for measures to protect the population, as well as clearly defining solutions from a professional standpoint,” the audit report of the Ministry of Foreign Trade and Economic Relations states.
