Flanders Publishes Industrial Emissions Directive Decree For Site Environmental Management

The measure is relevant to chemicals, metals, food, energy, waste and other regulated manufacturing sites. It changes the statutory architecture for environmental coordinators, environmental management systems, audits and annual environmental reporting. Important details still depend on implementing decisions, so operators should prepare without treating every enabling provision as an immediate duty.

How The Decree Changes Environmental Governance

Operators of Class 1 installations or activities must appoint an environmental coordinator, subject to category exemptions that the Government may establish. The Government will identify which Class 2 installations require a coordinator.

A permitting authority may also impose the role on another installation where its nature, environmental effects or environmental aspects justify it. The coordinator may be an employee or an external person. One coordinator may cover multiple installations where quality is not compromised, and an authority may require a shared coordinator for installations forming an environmental-technical unit.

The role includes monitoring legal compliance, reporting deficiencies, proposing remedies, supporting environmental policy, advising on environmental aspects and assisting official evaluations.

The previous framework already used coordinators and reporting. The new decree updates definitions, broadens the governance basis and aligns it with Directive (EU) 2024/1785, which amends the Industrial Emissions Directive, and with the voluntary EU Eco-Management and Audit Scheme.

Management Systems, Audits And Annual Reports

The decree defines the minimum purpose of an environmental management system, but the Flemish Government must decide which installations need one and how detailed it must be. It will also determine where verification, validation, certification or periodic audit is required.

Unless the Government provides otherwise, preparation, maintenance and audit costs fall on the operator, although subsidies may be available within budget limits.

For annual environmental reports, the Government will designate covered installations and required data. Where figures rely on measurements, operators must identify the method. Where they rely on calculations or estimates, operators must disclose the underlying data and method.

What Industrial Operators Should Do Before Commencement

Classify each Flemish site, identify the current coordinator arrangement and compare existing management systems with the new statutory functions. Inventory environmental reports, calculation methods, audit schedules and personal data held about coordinators.

Contracted coordinators and certification providers should check capacity before implementing rules expand demand. Operators should also separate requirements stated directly in the decree from category lists, exemptions, competence criteria and audit frequencies that remain for Government action.

The main near-term risk is designing a programme around assumptions that secondary measures later change. A modular gap assessment can identify the data, roles and controls that are stable while leaving configurable elements open until the implementing measures arrive.

Summary

Flanders has enacted its Industrial Emissions Directive decree, but the new duties are not yet applicable. Operators should retain current controls, map environmental-management gaps and monitor the commencement decision and implementing measures, with entry into force required no later than 1 January 2027.