What IED 2024 Means for Your Daily Practice

The revised Industrial Emissions Directive (IED - Directive 2024/1785) fundamentally changes how you work as a prevention advisor or environmental coordinator. Starting from 2027-2028, new obligations will directly impact your tasks and responsibilities.

This practical guide helps you navigate the transition smoothly while maintaining compliance.

New Environmental Coordinator Tasks: Direct Implementation

Task 8: Substances of Concern Strategy - Step-by-Step Plan

What you need to do concretely:

1. Create Inventory (deadline: before EMS implementation)

   • Compile complete overview of all substances used
   • Check each substance against new “substances of concern” definition
   • Document quantities and applications

2. Conduct Risk Analysis

   • Assess health and environmental risks per substance
   • Prioritize substances based on risk scores
   • Document findings for audit purposes

3. Develop Reduction Strategy

   • Find safer alternatives for high-risk substances
   • Propose emission reduction measures
   • Create implementation timeline with concrete milestones

Task 9: Environmental Management System (EMS) Coordination

Practical Implementation Steps:

For M1 Companies (IED-obligated):

• July 1, 2027: EMS fully implemented
• July 1, 2028: First external audit
• Subsequently: 3-yearly external audits

For M2 Companies (Class 1 with EC):

• March 31, 2028: EMS risk assessment completed
• Annually before April 1: Internal assessment via EC report

Task 10: Expert Assessment - Practical Approach

Annual Evaluation Points:

• Compliance with environmental policy and program
• Effectiveness of environmental management measures
• Compliance with environmental legislation
• Performance indicators and objectives
• Management reporting with recommendations

Environmental Management System (EMS): From Theory to Practice

Mandatory EMS Components Checklist

✓ Environmental Policy Objectives

• Formulate SMART objectives for continuous improvement
• Develop measurable performance indicators
• Link to business strategy

✓ Substances of Concern Inventory

• Use new definition from VLAREM II
• Include substances from REACH, CLP, and OSPAR lists
• Update at least annually

✓ Risk Assessment

• Methodology for health and environmental impact
• Quantify where possible
• Document uncertainties

✓ Alternatives Analysis

• 5-yearly evaluation of substance of concern replacement
• Cost-benefit analysis of alternatives
• Implementation roadmap when alternatives are available

✓ EC Recommendations Follow-up

• Systematic registration of all EC recommendations
• Status tracking and implementation timelines
• Reporting on executed actions

✓ Energy Integration

• Link with existing energy management system
• Identify synergies between environmental and energy goals
• Integrated reporting

Substances of Concern: New Definition and Consequences

Practical Identification of Substances of Concern

Check your substances against:

• CMR substances category 1A/1B
• Endocrine disruptors (ED HH/ENV category 1)
• PBT/vPvB and PMT/vPvM substances
• SVHC candidate list (regularly updated)
• REACH restriction annex XVII
• POP regulation annexes I-III

Obligations per Company Type

All companies with substances of concern:

• Limit use as much as possible
• Implement safer alternatives when available
• 5-yearly substitutability analysis

When no alternatives exist:

• Implement emission reduction measures
• Regular evaluation of measure effectiveness
• Maintain extensive documentation

Training and Competencies: What’s Changing?

New Training Requirements

Revised Basic Training:

• New study directions in VLAREM II annex 4.1.9.2.2
• Required work experience depending on diploma and EC type
• Transition arrangement for existing environmental coordinators

Updated Additional Training:

• Focus on substances of concern management
• EMS implementation and auditing
• Better defined thesis work

Recognition Abolished - New Conditions

EC recognition disappears from VLAREL. New conditions are included in VLAREM II:

• Application of codes of good practice
• Documentation requirements and signing
• Confidentiality obligations
• Professional independence

Timeline and Deadlines: Your Action Plan

Short Term (2025-2026)

• Now: Begin substances of concern inventory
• 2025: Follow new/revised EC training programs
• 2026: Start EMS development for early implementation

Medium Term (2027-2028)

• July 1, 2027: M1 companies EMS implemented
• March 31, 2028: M2 companies risk assessment completed
• July 1, 2028: First external audits M1 companies

Continuous Obligations (from 2028)

• Annually before April 1: EMS assessment M2 companies
• Every 3 years: External audits M1 companies
• Every 5 years: Substances of concern evaluation

Software and Tools: Digital Support

For efficient implementation of these new requirements, digital support is essential. Specialized software can help with:

• Automated substances of concern inventory
• EMS management and documentation
• Compliance tracking and reporting
• Audit preparation and follow-up

NextSDS offers specialized solutions that help you with practical implementation of the new IED requirements, from substance inventory to complete EMS management.

Key Changes in Environmental Coordinator Role

From Recognition to Integration

The most significant change is the abolition of environmental coordinator recognition. This means:

What disappears:

• Formal recognition system through VLAREL
• Separate recognition procedures
• Administrative recognition burden

What’s integrated:

• Requirements moved directly into VLAREM II
• Streamlined competency framework
• Focus on practical capabilities over administrative status

Enhanced Responsibilities

Environmental coordinators gain three critical new responsibilities that require immediate attention:

1. Strategic Substance Management - Moving beyond basic compliance to strategic reduction planning
2. EMS Coordination - Taking leadership in environmental management system implementation
3. Independent Assessment - Providing objective evaluation of environmental performance

Practical Implementation Strategies

For M1 Companies (IED-obligated)

Immediate Actions (2025):

• Conduct gap analysis against new EMS requirements
• Begin comprehensive substances of concern inventory
• Plan external auditor selection process

Preparation Phase (2026-2027):

• Implement EMS components systematically
• Train staff on new procedures
• Establish monitoring and reporting systems

Compliance Phase (2027-2028):

• Finalize EMS implementation by July 1, 2027
• Prepare for first external audit by July 1, 2028
• Establish 3-yearly audit cycle

For M2 Companies (Class 1 with EC)

Strategic Planning (2025-2026):

• Assess EMS requirements specific to your operations
• Integrate with existing management systems
• Plan resource allocation

Implementation (2027-2028):

• Complete risk assessment by March 31, 2028
• Establish annual review procedures
• Create EC reporting framework

Substances of Concern Management: Practical Framework

Identification Process

Step 1: Comprehensive Inventory

• Review all raw materials, intermediates, and products
• Check safety data sheets for concerning components
• Cross-reference with updated regulatory lists

Step 2: Risk Prioritization

• Assess exposure potential and hazard severity
• Consider regulatory timeline pressures
• Evaluate substitution feasibility

Step 3: Action Planning

• Develop substance-specific reduction strategies
• Set realistic but ambitious timelines
• Establish monitoring and review mechanisms

Documentation Requirements

Essential Records:

• Complete substance inventory with classifications
• Risk assessment methodologies and results
• Alternative analysis reports
• Implementation progress tracking
• Review and update schedules

Technology Integration and Digital Solutions

EMS Software Benefits

Modern EMS software platforms provide:

• Automated Compliance Tracking - Real-time monitoring of regulatory requirements
• Integrated Reporting - Streamlined preparation of audit and regulatory reports
• Substance Database Management - Automated updates of regulatory classifications
• Performance Analytics - Data-driven insights for continuous improvement

Implementation Support

Digital tools are particularly valuable for:

• Managing complex substance inventories
• Tracking multiple compliance deadlines
• Coordinating between different management systems
• Preparing audit documentation efficiently

Common Implementation Challenges and Solutions

Challenge 1: Resource Allocation

Solution: Phased implementation approach with priority focus on high-risk areas

Challenge 2: Staff Training

Solution: Structured training program combining regulatory knowledge with practical application

Challenge 3: System Integration

Solution: Leverage existing management systems and gradually integrate new requirements

Challenge 4: Documentation Burden

Solution: Implement digital documentation systems with automated data collection where possible

Conclusion: Turning Compliance into Competitive Advantage

The new Industrial Emissions Directive brings significant changes, but with proper preparation and tools, you can transform these challenges into opportunities for improved environmental performance.

Your Next Steps:

1. Start substances of concern inventory immediately
2. Plan EMS development according to your company category
3. Invest in training and new competencies
4. Consider digital tools for efficient implementation

The transition to the new system requires action, but with this practical guide, you’re well-prepared for the future of industrial environmental management.

Remember: Early preparation and systematic implementation will not only ensure compliance but can also create competitive advantages through improved efficiency and environmental performance.