Pravilnik o minimalnim zahtjevima energetske efikasnosti zgrada
Six requirements from the regulation in force. The two top rows, taken together, produce a conclusion that appears nowhere in the text as a sentence — it is below the table.
| What is regulated | Value | Test method |
|---|---|---|
| Air exchange while people are presenthow many times per hour the air must be fully replaced | 0,5h⁻¹ | Calculation |
| Airtightness with mechanical ventilationair leakage at 50 Pa pressure difference | ≤ 1,5h⁻¹ | MEST EN ISO 9972 |
| Air exchange when nobody is present | 0,3h⁻¹ | Calculation |
| Airtightness without mechanical ventilation | ≤ 3,0h⁻¹ | MEST EN ISO 9972 |
| Heat recoveryonly under four conditions at once, including total airflow above 2500 m³/h — a single apartment never reaches that | > 50% | Unit efficiency |
| Condensation on internal surfaceselements are designed so that it is prevented | not permitted | MEST EN ISO 13788 |
The conclusion from the two highlighted rows. The building must be airtight — no more than 1.5 volumes of leakage per hour. And it must simultaneously deliver half an air change per hour while people are inside. Through gaps, that volume physically does not add up. So an airtight building must have mechanical ventilation — not because it is written down, but because otherwise two requirements cannot be met at the same time.
Source: «Pravilnik o minimalnim zahtjevima energetske efikasnosti zgrada», «Službeni list Crne Gore» No. 47/2024 — articles 10, 11, 20 and 23. The conclusion is ours; no explicit duty to install mechanical ventilation in housing appears in the text. The heat-recovery requirement does not apply to an ordinary apartment: the 2500 m³/h threshold concerns buildings, not dwellings.
Umweltbundesamt · classes under VDI 2719
Window sound insulation in decibels. Above are reference points for real constructions, below the classes manufacturers work with. All of it holds exactly until the sash is opened for ventilation.
VDI 2719 classes
What outdoor noise level counts as acceptable — WHO, 2018
The important part of this picture is not the numbers but the caveat beside them. The German agency states two things in sequence: a soundproof window works only while it is closed, and an airtight soundproof window suppresses natural air exchange and creates a condensation risk. The way out is named there too: either burst ventilation every few hours, or a sound-insulating supply unit for the bedroom delivering at least 50 m³/h. A class-6 window with the sash open all night is a class-1 window.
Sources: Umweltbundesamt, «Wissenswertes über die Schalldämmung von Fenstern» — all decibel figures and VDI 2719 classes come from there; WHO Environmental Noise Guidelines for the European Region, 2018 — all six values are classed there as strong recommendations. The 20–60 dB range in the document refers to windows in general, not to soundproof windows specifically; the bars follow those boundaries.
ISO 16890 · replaced EN 779:2012
The standard replaced EN 779:2012 and changed the logic itself: a filter is classified not by abstract efficiency but by the particle fraction it retains at least half of.
Class 1
ISO Coarse
coarse dust
Class 2
ISO ePM10
particles up to 10 µm
Class 3
ISO ePM2.5
particles up to 2.5 µm
Class 4
ISO ePM1
particles up to 1 µm
So where is the sea salt? The answer is not the expected one. Measurements of marine aerosol show its mass sits in particles larger than a micrometre: the main modes are at 1–2 µm and around 5 µm, and the supermicron fraction accounts for about nine tenths of the mass. Salt is therefore already captured at ePM10 and ePM2.5 level, and ePM1 adds not salt but combustion fines. The conclusion is not weakened by this but sharpened: on the coast the filter class matters, not the word «filter» in an apartment description.
Sources: ISO 16890 — replaced EN 779:2012 and has applied as the binding international standard since 2018 after an eighteen-month transition; a filter falls into a class with at least 50 % efficiency in its fraction. Marine aerosol particle sizes from field measurements published in Scientific Reports (2017). ePM1 as a reference for the second filter stage comes from VDI 6022 Part 1 and the revised VDI 3803 Part 4 (January 2023) — a recommendation for ventilation systems, not a standard for housing; the Montenegrin regulation sets no mandatory filter class for residential buildings.