During a special thematic session at the EUIndTech2025 conference in Cracow (June, 2025), Mr. Robert Pochyluk from the Polish Environmental Management Forum presented and discussed the consequences of upcoming legislative changes in environmental management systems, particularly in the context of integrating the EMAS system with the revised Industrial Emissions Directive (IED). These changes mean that previously voluntary environmental management systems will become mandatory for certain groups of enterprises, especially those required to hold integrated permits. We are at the threshold of a significant transformation of environmental practices in industry.
EMS as a Mandatory Tool
The EMAS system or ISO 14001, which for many years functioned as voluntary tools, are now being formally incorporated into legal obligations resulting from the revised IED directive. Article 14a of this directive imposes on operators of installations covered by the directive’s scope the obligation to implement an environmental management system – for each installation separately. This is a fundamental change, because until now organizations could apply one centralized system (for ISO 14001) covering the entire company structure. Currently, it may be necessary to adapt systems so that they individually cover each installation.
Required System Elements:
The environmental management system – according to the directive – must include, among others:
- Environmental policy objectives oriented toward continuous improvement of efficiency, including actions related to waste reduction, water reuse, emission reduction, and energy consumption reduction.
- Integration with energy management systems resulting from the energy efficiency directive.
- An inventory of hazardous substances used and risk analysis of their use, along with assessment of possibilities for their substitution.
- A transformation plan toward clean industrial technologies (here the European Commission still needs to specify details – deadline: end of 2025).
All this data will need to be publicly available – most likely in a form similar to the EMAS environmental statement. The European Commission has until the end of 2025 to specify this.
Deadlines:
The first compliance audits of environmental management systems must be conducted no later than July 1, 2027. This means that real preparations should begin no later than 2026, if not earlier. Delays may result not only in increased costs of certification services but also in the risk of failing to meet legal obligations.
Practical Effects of the Introduced Regulations for Companies:
- They elevate the status of environmental management systems, making them not only a management tool but also a formal requirement,
- They may lead to the need to reorganize ISO 14001 systems so that they cover each installation separately,
- They may force certification bodies and EMAS verifiers to expand the scope of services and assessment methodology,
- They may standardize the practice of administrative bodies, which have previously interpreted the significance of environmental systems differently when issuing permits.
Legal Context and National Implementation
The revision of the IED directive is to be implemented into Polish law by the end of 2026. It is expected that the changes will include amendments to the Environmental Protection Law (probably articles 204-214), determination of accreditation procedures for certification bodies, and principles for recognizing ISO 14001 systems and EMAS registration. Poland will have some degree of freedom in implementation, particularly regarding the recognition of certificates and verifiers.
This topic will be one of the important elements of the agenda for the upcoming “FUTURE WITH EMAS” conference, which is planned for November 6-7, 2025, in Warsaw. Reserve the date now and leave email through the contact form to receive further detailed information about the conference.
