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:

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
Conduct Risk Analysis
- Assess health and environmental risks per substance
- Prioritize substances based on risk scores
- Document findings for audit purposes
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:

Strategic Substance Management - Moving beyond basic compliance to strategic reduction planning
EMS Coordination - Taking leadership in environmental management system implementation
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:

Start substances of concern inventory immediately
Plan EMS development according to your company category
Invest in training and new competencies
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.