IED 2.0: EMS becomes mandatory for industries. Are you ready for July 2027?

IED 2.0: a major overhaul, not just a minor adjustment

The Industrial Emissions Directive (IED) is the European Union's primary regulatory tool for controlling and reducing pollutant emissions from industrial activities into the air, water, and soil. It applies to dozens of sectors, including energy, metals, mineral industries, chemicals, waste management, food processing, paper mills, and intensive livestock farming, among others.

The revised version, Directive (EU) 2024/1785, entered into force on August 4, 2024. Member states, including Belgium (Wallonia, Brussels, Flanders), have until July 1, 2026 to transpose it into their national law.

Compared to the 2010 directive, the changes are substantial

• Expanded scope: gigafactories (large-scale battery manufacturing), extraction of metals and industrial minerals, hydrogen production via electrolysis, and livestock farming with lowered thresholds
• Stricter performance requirements: new Environmental Performance Limit Values (EPLVs) now cover not only emissions but also water, energy, and raw material consumption, derived from Best Available Techniques (BAT) conclusions
• Modernized European pollutant reporting portal (replacing the E-PRTR)
• ‍And most importantly: the mandatory implementation of an EMS, with periodic external audits.

EMS requirements: what the directive actually mandates

Until now, structured environmental management was often a voluntary or sector-specific initiative. The IED 2.0 makes it a regulatory requirement for all affected facilities.

The EMS must, at a minimum, include:

• an environmental policy with goals for continuous performance improvement
• measures covering waste, raw materials, water, energy, soil, safety, and climate;
• performance indicators aligned with the benchmarking of sector-specific BAT conclusions;
• monitoring of the environmental coordinator's recommendations;
• documented preventive and corrective measures.

For IPPC installations (subject to the Integrated Pollution Prevention and Control protocol), additional obligations apply: an inventory of hazardous chemical substances present or emitted (including those covered by Article 57 of the REACH regulation), an assessment of risks to human health and the environment, an analysis of substitution possibilities, and for the largest sites, the development of a transformation plan toward sustainable, circular, and climate-neutral operations by 2050.

This EMS must be subject to an external audit conducted by an independent third-party body, first by no later than July 1, 2027, and then at least every three years.

ISO 14001, EMAS, or "IED" EMS: three paths to compliance

The directive does not formally mandate ISO 14001 certification. It requires an EMS based on the ISO 14001 or EMAS methodology (Eco-Management and Audit Scheme), with additional requirements specific to the IED.

In practice, there are three possible paths:

ISO 14001 (international environmental management standard)

A valid ISO 14001 certification can serve as proof of compliance, provided that the EMS fully integrates all specific IED requirements. This is the most well-established and widely recognized path on the market.

EMAS (EU Eco-Management and Audit Scheme)

‍EMAS builds on ISO 14001 and strengthens requirements for transparency, staff involvement, and public reporting of performance. It is considered fully compliant with IED 2.0, and even better aligned with its reporting expectations.

"IED" EMS without certification

‍It is possible to build an IED-compliant EMS without obtaining ISO certification. In this case, proof of compliance relies on a triennial external audit conducted by an independent third party. This path is less burdensome in the short term but requires an equivalent level of documentary rigor.

In practice, for companies starting from scratch, ISO 14001 certification remains the most structured approach. It provides a proven framework and offers immediate clarity to competent authorities.

The timeline: why July 2027 is a real deadline

• August 4, 2024: entry into force of Directive (EU) 2024/1785
• July 1, 2026: deadline for transposition by Member States (including the three Belgian regions)
• July 1, 2027: deadline for all IED installations (the EMS must be operational and have undergone an initial external audit)
• Every 3 years thereafter: renewal of the external audit

Building a compliant EMS, validated by internal and then external audits, typically takes between 12 and 24 months for a company starting from scratch: initial gap analysis, system structuring, team training and engagement, environmental data collection, definition of objectives and indicators, internal audit, and finally, an external audit by an accredited third party. The schedule is tight.

In Flanders, where the transposition of IED 2.0 is the most advanced at the regional level, IPPC installations are entering the M1 category (mandatory operational EMS by July 1, 2027, with a triennial external audit), while other Class 1 companies with an environmental coordinator fall under the M2 category (operational EMS by July 1, 2028, with an annual internal assessment). This distinction stems from Flemish transposition choices.

For Wallonia and the Brussels-Capital Region, the precise transposition procedures are expected by July 1, 2026, at the latest. The IED deadlines as set out in the European directive remain unchanged.

What this means for you

You operate an industrial site subject to the IED directive: chemicals, steel, metals, mineral industry, waste management, food processing, paper, intensive farming... The obligation applies to you, regardless of the region.

Non-compliance carries increased penalties: the directive provides for fines of up to 3% of the operator's annual turnover for the most serious infringements, as well as increased transparency of emissions data via the new European portal.

But there is another way to look at this obligation. A well-designed EMS does more than just tick a regulatory box. It improves real control over the site's environmental impacts, facilitates permit reviews, and positions the company proactively for future requirements, particularly those related to the new Environmental Performance Limit Values (EPLVs) and the 2050 transformation plan.

ABV Environment supports IED operators in their compliance with the revised directive: gap analysis against IED EMS requirements, development or strengthening of the system, preparation for internal and external audits, and coordination with the competent regional authorities (SPW in Wallonia, Brussels Environment, and the Department of Environment in Flanders).

Is your facility already engaged in an EMS process? Contact our teams to review your situation and define an action plan tailored to your schedule.