Management system guidance
6.0 Planning
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6.3 Planning of changes
Organizations change constantly – new equipment is installed, processes are modified, sites open or close, laws are amended and suppliers come and go. Clause 6.3 requires that, when your organization identifies a need for a change that affects, or could affect, its environmental management system, the change is carried out in a planned way. The change must be managed so that the EMS can still deliver its intended outcomes: enhanced environmental performance, meeting compliance obligations and achieving environmental objectives.
The standard notes that the need for change can come from inside or outside the organization, and that managing change is also addressed in a number of other clauses.
What changed in ISO 14001:2026
Clause 6.3 Planning of changes is new to ISO 14001:2026. ISO 14001:2015 dealt with change only in scattered places (mainly planned changes under operational control and changes considered when determining aspects); the 2026 edition now has a dedicated planning requirement, aligned with the harmonized structure used by ISO 9001, together with new Annex A.6.3 guidance listing typical sources of change and the clauses where change is managed.
Sources of change
Changes can be temporary or permanent, and planned or unplanned. Annex A.6.3 gives examples of changes that can affect environmental performance, which can be summarized as:
- New products, services, processes, operations, equipment or facilities, or changes to existing ones;
- Changes to compliance obligations, such as new legislation, permit conditions or customer requirements;
- New knowledge or information about environmental aspects, impacts, or risks and opportunities;
- Developments in knowledge and technology;
- Changes to the technical specification of materials or process inputs, such as a substitute chemical;
- Mergers, acquisitions, joint ventures or divestitures that change business assets;
- Changes in staff or external providers, including contractors;
- Business disruption, for example from supply chain problems, labor disputes, natural disasters, political unrest or war.
Planning a change
Before a change is made, your organization should evaluate what the change is intended to achieve and what its environmental consequences could be, so that the intended benefits are realized and any unwanted effects are prevented or minimized. A simple change request or management of change form works well for most organizations. It should prompt the person proposing the change to consider:
- The purpose of the change and its potential consequences, including any new or altered environmental aspects and impacts (see 6.1.2);
- Whether any compliance obligations are affected, for example the need to vary a permit or notify a regulator (see 6.1.3);
- Any risks and opportunities the change creates (see 6.1.4);
- The effect on environmental objectives and action plans (see 6.2.2);
- The resources, competence and training needed (see 7.1 and 7.2);
- Who needs to be told, internally and externally (see 7.4.2);
- Which procedures, work instructions, registers and other documented information must be updated (see 7.5);
- Changes to operational controls, including controls over external providers and contractors (see 8.1);
- Whether emergency arrangements need revising (see 8.2);
- Who will approve the change, when it will take effect, and how its success will be checked.
The level of planning should be proportionate. Replacing a light fitting needs little more than a note; installing a new paint line, switching to a new refrigerant or acquiring a new site needs a structured review with input from the person responsible for the EMS.
Unplanned changes
Not every change can be foreseen. Where an unintended change occurs – for example, a supplier withdraws a material at short notice, or a flood damages a waste storage area – your organization should review the consequences and act to mitigate any adverse effects. Where the change results in a nonconformity, handle it through 10.2 Nonconformity and corrective action.
Change in other clauses
Annex A.6.3 points out that requirements for managing change also appear in clauses 6.1.2 (environmental aspects), 7.4.2 (internal communication), 7.5.3 (control of documented information), 8.1 (operational control), 9.2.2 (internal audit program) and 10.2 (nonconformity and corrective action). Your change process should connect to these rather than duplicate them. Management review should also consider changes in external and internal issues and in compliance obligations (see 9.3).
You should seek and record evidence that your organization identifies changes that affect or could affect its EMS, from both internal and external sources; that changes are evaluated for their environmental aspects, compliance obligations, and risks and opportunities before they are implemented; that responsibilities, resources, communication and documentation updates are planned; that changes are approved and their effectiveness checked; and that the consequences of unplanned changes are reviewed and acted upon. Sample recent changes, such as new equipment or a new supplier, and trace them through the process.
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