Requirements for environmental management systems in accordance with IED & EMAS

The revised Industrial Emissions Directive (IED) introduces stricter environmental standards for industries by 2027. A mapping shows how EMAS aligns with these new requirements, offering a proactive path to compliance, transparency, and sustainability.

In a significant move towards a greener Europe, the revised Industrial Emissions Directive (IED) came into effect in August 2024, introducing inter alia more ambitious requirements to set emission limit values in permits and a stronger focus on resource efficiency for large industrial installations. With EMAS, companies subject to the revised IED are well prepared to implement the new mandatory requirements for having an environmental management system.

EMAS, the Eco-Management and Audit Scheme, is an EU-backed voluntary environmental management system aiming to improve the environmental performance of organisations. Participating organisations publish an annual environmental statement, including information on the environmental policy, targets and actions as well as a set of core environmental performance indicators regarding energy, emissions, water, biodiversity, material use and waste.

The revised Industrial Emissions Directive (IED) requires operators of IED installations to implement an envi-ronmental management system by 1 July 2027 with certain requirements established in the new legal text. This present analysis shows that EMAS is a well-suited environmental management system to fulfil these requirements. EMAS is consistent with recent BAT conclusions on environmental management and is more aligned with the IED requirements compared to ISO 14001. Out of the total 4,000+ organisations and 13,000+ sites currently EMAS-registered around 1,150 are also subject to the IED provisions.

The EMAS Helpdesk together with legal experts from the Austrian Ministry of Climate Action conducted a mapping, available for download here, illustrating a high level of correspondence and synergies between the revised IED and EMAS.

Key synergies between EMAS and the IED requirements for an environmental management system (art 14 a) include:

• Environmental management system: installations subject to the revised IED have to prepare and implement an environmental management system. The fundamental requirements for the envi-ronmental management system (e.g. policy, objectives, performance indicators, actions and public reporting) match those of EMAS.
• BAT conclusions: EMAS is a ready-to-use compliance solution already recognized by existing BAT conclusions, which also include specific environmental management system requirements. The General BAT conclusion for Environmental Management Systems in BAT 1 for surface treatment serves as a good example.
• Continuous improvement: both systems emphasise ongoing enhancements in environmental per-formance.
• Environmental performance tracking: EMAS's annual environmental statements match with IED's increased focus on performance indicators.
• Transparency: EMAS's public reporting aligns with the IED's push for greater transparency.
• Energy efficiency: EMAS and IED both include energy consumption and efficiency as relevant indica-tor of the environmental management system and foresee a continuous improvement in this area. In contrast, ISO 14001 does not necessarily contain energy performance tracking and measures.

However, some differences in the requirements of EMAS and IED have to be taken into account:

• Different scope: while EMAS refers to organisations that also encompass sites, the IED focuses on installations. If a site has several IED-installations, these may all be included in one EMAS-registration and in the environmental statement. To become IED-compliant, EMAS-registered or-ganisations need to fulfil all requirements not only at the site level but also at the installation level and might have to add granularity to their environmental management system and environmental statement, depending on their current practices.
• Hazardous substances: including a continuous improvement process concerning the handling of chemicals, which is based on a chemicals inventory of hazardous substances present in or emitted from the installation as requested by IED. Although EMAS does not specifically address chemical substances, EMAS-registered companies follow applicable laws, which often require comprehensive lists, assessments and safety data sheets. Therefore, EMAS-registered companies usually establish guidelines for the management of products and chemical substances already now and have lists to verify the presence of safety data sheets and follow the storage and management guidelines in-cluded therein. In this sense, organisations with EMAS have a very good basis for complying with this IED requirement.
• Transformation: the IED requires including in the environmental management system an indicative transformation plan on how the operator will transform the installation during the 2030-2050 pe-riod to contribute to the emergence of a sustainable, clean, circular, resource-efficient and climate-neutral economy by 2050. This plan is required as from 30 June 2030 under the IED. The environ-mental programme established under EMAS including related measures can be used as basis or framework for defining this transformation plan.

By addressing these areas, EMAS participants can ensure full compliance with the new IED requirements.

Early adoption of these enhanced environmental management practices not only ensures compliance but also drives competitiveness. By proactively implementing EMAS and addressing the additional IED require-ments, organisations can avoid future costs, streamline processes, and position themselves as industry leaders in sustainable practices.

As we move towards a more environmentally conscious industrial landscape, EMAS-registered organisations are well-positioned to lead the way. The synergies between EMAS and the new IED offer a clear path forward for sustainable, compliant, and competitive industrial operations across Europe.

To learn more, access the full mapping document here: Mapping of EMAS and IED requirements