Spectra-media: From 160 Employees to Cold Operation

Spectra-media d.o.o., until recently one of the key processors of electrical and electronic waste in Croatia in the segment of small electronic and IT equipment, has gone from full operation to a work ban and waves of layoffs in less than a year. After terminating its contract with the Environmental Protection Fund due to the collapse of the EE waste collection network, the State Inspectorate prohibited its processing despite having a valid authorization from the relevant ministry until 2027, permits, and available capacities. The documents confirming this were presented to us by Kerim Mujkić, the owner and director of Spectra-media, whom we visited earlier this year in search of information about the problems in the collection and processing of EE waste in Croatia and the difficulties the company is facing.

In the past year, at least a hundred people have lost their jobs at Spectra-media and its associated companies. The sequence of events was as follows: The Environmental Protection and Energy Efficiency Fund last year, after consulting with key stakeholders, redefined the prices for the processing and collection of EE waste, but they were lower than expected and announced. The cooperatives in waste collection did not want to work at the new prices and canceled their cooperation with Spectra-media, which then terminated its contract with the Fund.

– We had many meetings and discussions until they at one point came out with prices that we really could no longer work with. The recovery price was not as debatable as the collection price. We got very close, but in the final proposal, after a public consultation that was conducted in a very non-transparent manner, local collection was reduced from the initially proposed 425 euros per ton to 289 euros including VAT per ton, which is about 230 euros without VAT. Until then, the price, which included local collection and remote transport, was 345 euros including VAT – Mujkić told us.

When they conveyed this to the partners for collecting EE waste, gathered over the years into a quality network that collected such waste from citizens and companies free of charge throughout Croatia, there was astonishment. And the cancellation of cooperation.

– It is not the same to collect one ton of refrigerators or washing machines and one ton of mobile phones, printers, and small electronics. The difference is like when you need to pick a ton of watermelons or a ton of cherries, and the Fund equated that, it did not recognize it. Our collectors told us at the new prices that they could not work that way because they were barely covering themselves even with the old prices and began canceling our contracts. Most of them were engaged only in that business, they could not finance the cold operation, workers, vehicles, and they closed their companies – Mujkić recounted.

Collapse of the Collector Network

At that moment, Spectra-media practically loses its network of collectors, which prevents it from fulfilling its contractual obligation to collect EE waste throughout Croatia and within the legal deadline of at least 20 days for reporting waste weighing more than 30 kilograms. Consequently, the company notifies the Fund of its intention to terminate the contract. After the expiration of the notice period in February 2025, Spectra-media continued to receive for processing and collect from owners EE waste of the second, third, and sixth categories. For this, it regularly sent offers to owners and informed them that it was no longer the Fund’s contractual partner, similar to what it had done before when discarded photovoltaic panels and fluorescent bulbs began to appear as waste, which were not part of the contract with the Fund.

Before the termination of the contract, Spectra-media had 167 employees based on working hours, and its founders state that approximately as many people worked in the collector network. After the cessation of contractual obligations with the Fund in February 2025, a good portion of the companies and crafts from the collector network ceased operations, while others reoriented to new activities and reduced the number of employees.

Spectra-media continued to operate on a smaller scale as it has the necessary permits and authorizations for processing EE waste and has experience in providing services to commercial clients. Since it established a method for processing printer toners, it collaborates with various manufacturers and collectors of toner cartridges, who supply it with this consumable material for recycling from several European countries. It has also devised a process for recovering electronic cigarettes and other small devices with non-removable batteries, the success of which has been noted by e-cigarette manufacturers.

– Since the network for collecting EE waste of the second, third, and sixth categories has not been functioning since February last year, and recycling yards do not accept those categories of waste, problems in managing EE waste have arisen. The City of Zagreb realized that the Fund had not been resolving these issues for months and announced a tender for the disposal of these categories of waste at recycling yards. We applied, provided a competitive European price of 800 euros per ton, which includes collection, transport, sorting, and processing, and signed a contract. And then a state inspector visited us and said that we could not do that, that we could not process and collect waste because we do not have a contract with the Fund. He prohibited us from working, and we had to terminate the contract with the City, which has since had no solution for that waste – Mujkić explained.

Inspectorate Prohibited Work

This ban was imposed on them on September 30, and of course, Spectra-media appealed, but the appeal was rejected by first-instance and second-instance decisions. In short, despite having a valid authorization from the Ministry, necessary permits, and available capacities, Spectra-media’s work was prohibited due to the absence of a contract with the Fund, which the inspection treated for the first time in that oversight as an act necessary for conducting activities. The rejection of Spectra-media’s appeal – that it is incorrectly and without basis interpreted that the contract with the Fund is an act that, in accordance with the Waste Management Act, would be necessary for conducting activities – was not sufficiently explained. Meanwhile, the State Inspectorate, as noted by Spectra-media, had previously accepted the fact that the company processes waste for which it does not have a contract with the Fund, such as waste fluorescent bulbs and solar panels.

Legal ambiguities are not only present in the inspection procedure; they also exist in the public call of the Fund for the collection and processing of the second, third, sixth, and partially fourth and fifth categories of EE waste. In that call, issued after Spectra-media terminated the contract with the Fund, it is stated that a contract will not be concluded with any applicant who intends to recover EE waste at persons who have valid authorization from the Ministry and that the call is issued because processors of EE waste with contracts with the Fund do not have sufficient capacities for its processing.

– That last tender was issued in such a way that the waste must be exported. This is not explicitly stated anywhere, but it is said that it cannot be processed in Croatia by authorized processors. And regarding the work ban, to obtain a contract with the Fund, you must have the necessary authorization, and to obtain authorization, you must have permits. We were imposed a work ban because we did not have a contract even though we have both permits and authorization – Mujkić stated.

The Regulation on the Management of Special Categories of Waste in the Fund’s system indeed stipulates that the processing of these categories of waste is carried out only by a processor who has a contract with the Fund, but it also allows exceptions in cases where there is no capacity for processing with a processor with a contract. Furthermore, this regulation stipulates that EE waste collected in Croatia must be recovered and recycled in Croatia if there are capacities for it, without indicating that they must be under contract.

Difficult Adjustment

We also asked the Fund for Environmental Protection and Energy Efficiency to explain this proposition of the Public Call to us. In it, they stated that the provision of Article 97, Paragraph 14 of the Waste Management Act explicitly stipulates that ‘exceptionally, the Fund provides a collection network and processing for types of waste for which no authorization has been issued and for which there are insufficient capacities for processing in the Republic of Croatia by concluding contracts through conducted public calls’.

‘Therefore, the Fund, in accordance with the cited provision, prescribed the stated condition because the Republic of Croatia has run out of capacities for processing EE waste at the moment when the previous processor, as an authorized entity for the recovery processes of EE waste that are the subject of the public call, unilaterally terminated the contract for performing EE waste processing that it had concluded with the Fund,’ it is stated in the Fund’s response.

As we were informed by the Fund, based on this public call, the company M SAN Eko was selected for the disposal of EE waste, and a contract has already been signed with it.

Setting aside the interpretation of the provisions of the regulations, public calls, and decisions, the fact remains that Spectra-media has, in barely a year, gone from a successful company that had been operating properly for years to a situation where, due to disputes with the Fund and the ban from the State Inspectorate, its revenues have fallen so much that it had to significantly reduce the number of employees and will soon have to reorient its business. At this moment, it is engaged in processing waste received from abroad and outdated telephone exchanges that domestic operators are abandoning, as well as processing the remaining waste that was previously collected but not yet processed. Its plant in Virovitica, which opened in 2009 and is equipped with a complete processing line for that type of waste, is now threatened with closure.

– In those years, the unemployment rate in Virovitica was the highest in Croatia, around 33 percent. We employed mostly women who were losing jobs in the textile industry. We employed 160 people there, now there are 47, and when we finish all this that we are still processing before the delivered waste, there will be work for at most 20 people – Mujkić announced.

To fulfill obligations to employees, that is, for severance pay, Spectra-media has allocated significant financial resources. The continuation of business will not be jeopardized, but the adjustment period will be difficult. Mujkić and his family are engineering-oriented; they designed, planned, and produced or at least organized the production of most of all the crushing, screening, and hydro-separation material plants themselves. They also obtained a patent for the processing and recovery of printer toners and devised an innovative method for neutralizing discharged lithium batteries during the processing of EE waste. Unfortunately, some of their machines in the plant in Donja Bistra are not operational because they have no incoming waste due to the work ban, and some have already been dismantled. In the yard of the plant, containers for transporting EE waste, which Spectra-media designed and implemented into the collection network as a precaution and for fire protection after the first fire incidents during the transport of EE waste, have also been placed.

There is Work

– Now, after the work ban, we will have to lay off about sixty people. We are not allowed to process waste generated from devices placed on the market in Croatia even if we wanted to. And there is work, people are calling. We can process waste devices that have not been placed on the Croatian market, that is, only what has come from abroad. For example, electronic cigarettes from Europe or toners – Mujkić said.

Regardless of everything, at Spectra-media, they hope that they will still have opportunities to at least collaborate with domestic partners who have electronic devices for destruction, such as Customs, which seizes such devices when they are attempted to be illegally imported into Croatia, or with companies and institutions that periodically need a reliable partner for commission and selective destruction of devices containing confidential data. Until then, Mujkić announces that he will continue the legal battle against the unjust work ban and the unjustified conditions of the Public Call that have made it so difficult for Spectra-media to operate that it is working almost on a cold operation.