Overview of the current issues of the manufacturers of bricks and tiles in the Republic of Macedonia (delivered to the Prime Minister, Mr. Zoran Zaev, to the Deputy Prime Minister of the Government of the Republic of Macedonia in charge of economic affairs and coordination with the economic departments, Kocho Angjushev Ph.D., the Ministry of Economy and the Ministry of Finance on 31 July 2018) – The expertise gave a review of the production and trade exchange of bricks and tiles in the Republic of N. Macedonia in the last several years, the reasons for the decrease of the production and export of bricks in these years, with concrete proposals for overcoming such problems in this industrial branch.

Opinion on the Draft – text of the Law on physical and urban planning (sent on ENER on 10 August 2018) – companies members of the Association supported the initiative of the Ministry of Transport and Communications to prepare new modern Law on physical and urban planning which will enable faster, more efficient and more transparent proceedings for adopting the urban plans. The Association gave concrete proposals in the direction of defining certain postulates that represent a blend of the previous and the new law in order to enable continuity of the proceedings, the acquired rights of the participants in construction, liberalization of certain urban elements, monitoring and developing the urban space, data collection, modernizing and simplifying the procedures.

Proposals on the Draft – text of the Law on energy efficiency (sent on ENER on 27 December 2018) – The Association proposed provisions regulating energy efficiency of buildings, including energy efficiency of installation systems to be regulated in the Law on construction. Additionally, the Association proposed the Law on energy efficiency only to be a legal frame and to give strategic directions in the field of energy efficiency, and all details, as well as specific issues to be regulated in the rulebooks for implementing the Law, to envisage obligation for the buildings in the public sector for carry out controls for energy efficiency in precisely determined legal deadlines, and to define certain terms in the Law aiming to enable its more proper and more efficient implementation.

Proposals for amending the Draft – law on urban planning (delivered to the Ministry of Transport and Communications on 10.4.2019) – the Association prepared proposals aiming to enable efficient and practical law on urban planning, considering the provisions regulating the time frame for preparing and adopting urban plans, increasing the expertise in the field, financing of the plans, defining the competences of the public institution for urbanism, provisions regulating misdemeanours etc. 

Comments and proposals concerning the development and adoption of the bylaws to implement the Law on Urban Planning (sent to the Ministry of Transport and Communications on 31/03/2020) – The Association provided constructive input for the development and adoption of the bylaws to implement the Law on Urban Planning (Official Gazette of the RNM No. 32/2020 of 10/02/2020) by sending comments and proposals of the companies concerning specific issues that should be (further) regulated by the bylaws, aiming at efficient and unhindered implementation of the Law in practice.

Comments and remarks concerning the draft Rulebook on Urban Planning (sent to the Ministry of Transport and Communications on 30/06/2020) – Pursuant to the consultations held with the companies and the discussion at the online work meeting of 16/06/2020, the Association prepared and sent comments and remarks concerning the draft Rulebook on Urban Planning that argue for further specification of the provisions and clarification as to what type of document (urban plan or urban project) is developed for state and regional roads and when such document is developed, who develops the building feasibility study, as well as what is the latest classification of buildings and purposes based on, particularly concerning designations А2.1, А2.2, and А2.3.

Opinion on the draft Methodology for Real Estate Valuation (sent to the Ministry of Transport and Communications on 03/03/2021) – Following the work meetings and examination of the proposed text, the Association prepared and sent an Opinion on the draft Methodology for Real Estate Valuation to the Ministry of Transport and Communications greeting the efforts of the competent ministry in developing a new methodology based on European and international valuation standards, but also arguing for further regulation to ensure applicability in line with the specific characteristics of the area of application and for taking into consideration the real estate valuation practices to date.

Initiative concerning the conditions for recognizing and validating construction product certificates in the Republic of North Macedonia issued in the European Union and the Western Balkan region (sent to the Ministry of Economy on 08/04/2021) – Under the priorities of North Macedonia’s Chairmanship of the Central European Free Trade Agreement (CEFTA) in 2021, the Association prompted the Ministry of Economy to advocate elimination of the non-tariff barriers in the regional countries that hinder export and free trade of construction products, and to launch activities toward reciprocal treatment of construction products that are imported and possess CE certificate, as well as of construction products imported from Western Balkan countries, until the barriers are lifted and the country joins the EU as a full member state. 

Opinion on the draft Law on Construction and on the draft Rulebook on Building Classification (sent to the Ministry of Transport and Communications on 29/04/2021) – In general, the business community concluded that the proposed legislation, to a certain extent, does not meet the desired goals and does not offer solutions to some of the biggest problems that construction companies face daily. Aiming to ensure legal certainty, unhindered operation of the real sector, uninterrupted implementation of investment projects, as well as to overcome the frequent amendments to the law, the business community suggested that the latest Law on Construction, being a general law in the field of construction, should suitably treat and regulate the construction of buildings in every segment of construction (civil engineering, building construction, and hydropower projects). Current practice should serve as basis and by analyzing and understanding the problems of the companies and the administrative obstacles, the Law should regulate construction instead of presenting completely new conceptual solutions for nearly every issue in that regard, which may lead to effects opposite to the desired ones and to discontinuity in the operation of the business entities. Considering that buildings as a finished product are the essence of every regulation in the field of construction, due to which building classification is expected to be a core document, that is, a central document in the regulatory system, and a document that covers all types of buildings, companies are still examining the classification proposed in the draft Rulebook on Building Classification from several aspects: 1) building significance defined by the proposed law, 2) building function, 3) risk from complete or partial destruction related to losing human lives and/or functionality disruptions, and 4) need for unhindered functioning of vital services and infrastructure during and immediately after natural and technological disasters. 

Initiative for introducing anti-crisis economic measures to support the construction sector (sent to Mr. Fatmir Bitikji, Deputy President of the Government in charge of economic affairs, coordination of the economic sectors, and investments, to Mr. Fatmir Besimi, Minister of Finance, and to Mr. Blagoj Bochvarski, Minister of Transport and Communications on 23/06/2021) - Considering the current developments in this quite important business sector, the members of the Association of Construction, Building Materials and Non-metal Industry expressed serious concern over the situation and future of Macedonian construction, pointing out that construction was not immune to the Covid-19 pandemic, which further contributed to the already stagnating growth dynamic in the sector, which started to decline from the last quarter of 2019. Apart from the business environment and the new pandemic working conditions related to the organization of work such as the measures and recommendations against the coronavirus and less public procurements for construction works, construction companies are currently mostly concerned about the price increases in building materials. According to the analysis of the Association, the price of steel sections and pipes over the period 03/2020-03/2021 grew 33%, then increased by additional 33% in the period 03/2021-06/2021, and by the end of the year, according to the announced movements, this price increase is expected to reach 95%. According to the analysis and the announced developments, prices from the start of the pandemic by the end of 2021 are expected to increase 55% in formwork, 57.5% in geocomposite, up to 61.3% in EPS insulation, 44% in protective coatings, 47% in the polymer-modified bitumen, and up to 52% in metal sections. Therefore, considering that the figures confirm the unquestionably alarming situation in construction resulting from the price increases, construction companies proposed urgent introduction of support measures for the sector to deal with the price increases and to this end, they proposed to the authorities to consider the possibility of introducing preferential VAT rate on the turnover and import of construction products until the market of construction products stabilizes. Moreover, the tender documentation in procedures for awarding public procurement contracts, pursuant to Article 119 of the Law on Public Procurements (Official Gazette of the Republic of Macedonia No. 24/2019 and Official Gazette of the Republic of North Macedonia No. 87/2021), should lay down possibility for price correction, in order to ensure amendments to public procurement contracts in case of price increases without needing a new public procurement procedure.

Proposals and comments concerning the draft Law on Technical Requirements for Products and Conformity Assessment (sent to the Ministry of Economy on 06/07/2021) – Concerning the text of the draft Law on Technical Requirements for Products and Conformity Assessment published on the website of the Unique National Electronic Registry of Regulations (ENER) on 16/06/2021, following the consultation and examination of the proposed legislative act, the member companies provided comments and proposals arguing for further specification of certain provisions in line with the current practice and regulations that already cover part of these issues concerning construction products.