NORTH MACEDONIA Trends and Developments Contributed by: Ana Tosic Chubrinovski, Ivica Jevtic, Ljupka Naumoska Gjorgjievska and Marija Boceska, JPM Partners North Macedonia
A cornerstone of the new regulatory architecture is the preparation of the National Strategy for Geological Exploration and Sustainable Utilisation and Exploita - tion of Mineral Resources 2025–45 (the “Strategy”). The Strategy is being developed by the Macedoni - an Academy of Sciences and Arts (MASA) with the engagement of more than 20 distinguished scientists and experts in geology, mining, environmental protec - tion, economics and law. This document represents the first comprehensive scientific and strategic frame - work for the development of mining in independent Republic of North Macedonia. The Strategy establishes long-term objectives for geo - logical exploration and mineral exploitation, defines priority mineral resources and key geological prov - inces, provides guidance for infrastructure develop - ment linked to mining activities – including transport networks, energy supply and water management – and sets clear sustainability criteria balancing eco - nomic interests, environmental protection and the public interest. These functions collectively position the Strategy as the principal roadmap for the sector’s development over the next two decades. The drafting process has been fully transparent and inclusive, reflecting the broader objectives of the coun - try’s reform transition. The Ministry and MASA have actively involved the academic community, civil soci - ety organisations, professional associations, industry representatives and local authorities, with comments and observations considered through multiple con - sultation cycles. Particular focus has been placed on alignment with EU regulatory requirements and the Critical Raw Materials Act (CRMA), the application of stringent environmental standards and risk manage - ment mechanisms, and enhanced transparency in concession allocation and the management of public resources. The Strategy explicitly affirms the principle that the economic benefits of mining constitute a legitimate objective only when realised within the framework of high environmental standards and the effective pro - tection of the public interest. For investors, the adop - tion of such a document – prepared by the country’s highest scientific institution – serves as a strong signal that mining policy is not driven by ad hoc political
considerations but rests upon analytical foundations, long-term planning horizons and scientific expertise. A particularly significant element of the reform agen - da is the transposition of Regulation (EU) 2024/1252 (CRMA). Through the CRMA, the EU establishes quantitative targets for domestic sourcing, process - ing and recycling of critical and strategic materi - als, while simultaneously facilitating the inclusion of “trusted partners” from third countries into European supply chains. Alignment with this framework enables the Republic of North Macedonia to position itself as a reliable partner within the European raw materials ecosystem. Such alignment implies full compatibility with the due diligence standards applicable to European industrial purchasers, access to EU programmes supporting financing and project guarantees in the field of criti - cal materials, an enhanced negotiating position for the conclusion of long-term off-take agreements, and substantive integration into the broader European strategy on energy and raw materials security. Aligning Mining Operations With Environmental and ESG Norms The integration of environmental protection as a cen - tral pillar of sectoral policy is primarily rooted in the Law on Environmental Protection, which constitutes the core statute in this area. It transposes key Euro - pean directives, including the Environmental Impact Assessment (EIA) Directive, the Strategic Environ - mental Assessment (SEA) Directive, the Integrated Pollution Prevention and Control/Industrial Emissions Directive (IPPC/IED) framework for integrated pollu - tion prevention and control, as well as directives on industrial emissions, waste management and water quality. In the mining context, these provisions have concrete and far-reaching implications. Projects involving the opening, expansion or substan - tial modification of mines are generally classified as activities requiring a full EIA procedure, including the preparation of a detailed study, public presentation and formal public participation in the decision-making process. Larger mining facilities and associated pro - cessing plants, such as flotation units and concentra - tors, are treated as high-pollution installations and are
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