ECO-Management and Audit Scheme (Regulation)

Organisations can improve their environmental performance - without being statutorily forced - by participating in the voluntary European certifications system EMAS (Eco-Management and Audit Scheme): The submitted Proposal for a Regulation enables also organisations seated outside the EU to participate in EMAS. For organisations with sites located in one or more Member States registration procedures are being simplified as they may apply for one single corporate registration of all sites ("collective registration"). Rules for small organisations are being simplified, too, by applying exceptions. In addition, they will report on their environmental performance on the basis of so-called "core indicators" which are newly introduced.


The option for collective registration as well as the possibility to participate in EMAS from outside the EU increases the attractiveness of EMAS. However, the new "core indicators" are critical since they do not necessarily provide a proper reflection of environmental performance and, above all, impose further disclosure obligations on organisations. Instead, any additional reporting duties should be waived. The newly stipulated exceptions for small organisations are not properly designed and should be revised.