STP COMPLIANCE EHS REGALERT ROUND-UP
JANUARY 31ST 2026
New ISO 14001:2026 – Environmental Management Systems Standard Coming in April
On January 5, the Final Draft International Standard for ISO 14001 was released for an eight-week review and comment period, with final publication currently expected in April 2026. While the transition period is still under discussion, if a three-year transition is confirmed, all certifications issued to ISO 14001:2015 will need to be transitioned to the new edition by May 2029 to remain valid.
The anticipated ISO 14001:2026 revisions include editorial updates and improved terminology to enhance clarity, readability, and alignment with other management system standards, along with an expansion of several existing concepts. Key expected changes include:
- Enhanced requirements to help organizations consider how environmental conditions—such as pollution levels, natural resource availability, climate change, and biodiversity—affect their operations and how their activities impact the environment;
- A strengthened expectation to consider a life cycle perspective when determining the scope of the environmental management system (EMS);
- A requirement to manage changes that affect, or could affect, the EMS in a planned and systematic manner, whether arising from internal or external sources;
- Revisions for controlling or influencing externally provided processes, products, or services relevant to the EMS; and
- A requirement to define audit objectives for each internal audit.
In a related update, a review of ISO 45001:2018 – Occupational Health and Safety Management System has been initiated, but a published version is not expected until 2027.
On January 5, the Final Draft International Standard for ISO 14001 was released for an eight-week review and comment period, with final publication currently expected in April 2026. While the transition period is still under discussion, if a three-year transition is confirmed, all certifications issued to ISO 14001:2015 will need to be transitioned to the new edition by May 2029 to remain valid.
The anticipated ISO 14001:2026 revisions include editorial updates and improved terminology to enhance clarity, readability, and alignment with other management system standards, along with an expansion of several existing concepts. Key expected changes include:
- Enhanced requirements to help organizations consider how environmental conditions—such as pollution levels, natural resource availability, climate change, and biodiversity—affect their operations and how their activities impact the environment;
- A strengthened expectation to consider a life cycle perspective when determining the scope of the environmental management system (EMS);
- A requirement to manage changes that affect, or could affect, the EMS in a planned and systematic manner, whether arising from internal or external sources;
- Revisions for controlling or influencing externally provided processes, products, or services relevant to the EMS; and
- A requirement to define audit objectives for each internal audit.
In a related update, a review of ISO 45001:2018 – Occupational Health and Safety Management System has been initiated, but a published version is not expected until 2027.
Colorado’s New Health-Based Air Pollution Control Program Adds June 2026 Reporting
Through a set of related rulemaking directed by HB22-1244, the Air Pollution Control Division of Colorado has established most of the regulatory framework for the new Priority Toxic Air Contaminants (PTAC) Program. When complete, the Program will impose toxicity-driven emission standards and reporting requirements that have no federal equivalent. Adoption of the final element, emissions control rules, is scheduled for April 2026.
The first compliance date under Program rules is June 30, 2026, when enhanced annual toxic air contaminant (TAC) reports are due for the 2025 reporting year. Amendments to Regulations 3 and 7, effective June 14, 2025, expanded TAC applicability, among other revisions, to nearly any Colorado facility that emits any PTACs (as identified in the new Regulation 30: formaldehyde, benzene, hydrogen sulfide, ethylene oxide, and hexavalent chromium). Amendments effective January 14, 2026, include updates to emission-reduction credit requirements and new definitions related to socioeconomically vulnerable communities.
The proposed emission control rules, which will fully activate the control requirements mandated by HB22‑1244, include location-based applicability criteria and revised limits for new and modified sources that are more stringent than the federal limits. For existing sources, emission thresholds are based on actual annual emissions. New provisions outline actions to take if future emissions exceed the threshold, including new reporting and retrofit options.
Through a set of related rulemaking directed by HB22-1244, the Air Pollution Control Division of Colorado has established most of the regulatory framework for the new Priority Toxic Air Contaminants (PTAC) Program. When complete, the Program will impose toxicity-driven emission standards and reporting requirements that have no federal equivalent. Adoption of the final element, emissions control rules, is scheduled for April 2026.
The first compliance date under Program rules is June 30, 2026, when enhanced annual toxic air contaminant (TAC) reports are due for the 2025 reporting year. Amendments to Regulations 3 and 7, effective June 14, 2025, expanded TAC applicability, among other revisions, to nearly any Colorado
facility that emits any PTACs (as identified in the new Regulation 30: formaldehyde, benzene, hydrogen sulfide, ethylene oxide, and hexavalent chromium). Amendments effective January 14, 2026, include updates to emission-reduction credit requirements and new definitions related to socioeconomically vulnerable communities.
The proposed emission control rules, which will fully activate the control requirements mandated by HB22‑1244, include location-based applicability criteria and revised limits for new and modified sources that are more stringent than the federal limits. For existing sources, emission thresholds are based on actual annual emissions. New provisions outline actions to take if future emissions exceed the threshold, including new reporting and retrofit options.
China Addresses Hazardous Chemical Safety
Effective on May 1, 2026, China has approved the Hazardous Chemicals Safety Law (危险化学品安全法通), issued under Decree of the President of the People’s Republic of China No. 64 on December 27, 2025. This Law is the country’s first national legislation dedicated specifically to hazardous chemical safety management. It consolidates existing regulatory requirements and introduces new obligations to strengthen risk prevention, accountability, and the lifecycle management of hazardous chemicals. It specifies that a hazardous chemicals catalogue will be established and maintained by the Ministry of Emergency Management (MEM), with a management system based on standard hazard identification and classification. The Law also strengthens safety requirements for the handling and disposal of hazardous chemicals, requiring enterprises to implement effective measures to prevent leaks, protect against corrosion, monitor, and respond to emergencies. In addition, the Law tightens controls on hazardous chemical transportation, mandating satellite tracking, prohibiting interference with monitoring systems, and limiting continuous nighttime driving. Chemical industrial parks that fail to meet minimum safety risk Standards may be ordered to rectify deficiencies or face revocation of their designation and public disclosure.
Other recent actions addressing hazardous chemicals with a focus on emissions include:
Effective on May 1, 2026, China has approved the Hazardous Chemicals Safety Law (危险化学品安全法通), issued under Decree of the President of the People’s Republic of China No. 64 on December 27, 2025. This Law is the country’s first national legislation dedicated specifically to hazardous chemical safety management. It consolidates existing regulatory requirements and introduces new obligations to strengthen risk prevention, accountability, and the lifecycle management of hazardous chemicals. It specifies that a hazardous chemicals catalogue will be established and maintained by the Ministry of Emergency Management (MEM), with a management system based on standard hazard identification and classification. The Law also strengthens safety requirements for the handling and disposal of hazardous chemicals, requiring enterprises to implement effective measures to prevent leaks, protect against corrosion, monitor, and respond to emergencies. In addition, the Law tightens controls on hazardous chemical transportation, mandating satellite tracking, prohibiting interference with monitoring systems, and limiting continuous nighttime driving. Chemical industrial parks that fail to meet minimum safety risk Standards may be ordered to rectify deficiencies or face revocation of their designation and public disclosure.
Other recent actions addressing hazardous chemicals with a focus on emissions include:
- The updated Emission Standard of Air Pollutants for the Lead and Zinc Industry, effective January 1, 2026, tightening concentration limits for organized (stack) emissions, while also introducing—for the first time—explicit control requirements for fugitive emissions such as leaks, dust, open storage, material handling, and transfer operations.
- Bans beginning on July 1, 2026, on the use of Hydrochlorofluorocarbons (HCFCs) or mixed solvents containing HCFCs as cleaning agents ( Announcement No. 30 of 2025), and the manufacture of extruded polystyrene foam products that use HCFCs, or mixtures containing HCFCs as foaming agents ( Announcement No. 31 of 2025), and
- The release of the List of Priority Controlled Chemicals (Third Batch), adding to the final list with 23 categories of chemical substances, covering carcinogens such as 1,1,2,2-tetrachloroethane and tris(2,3-dibromopropyl) phosphate, as well as endocrine disruptors such as bisphenol A and di(2-ethylhexyl) phthalate (DEHP). These substances are commonly used across many industrial sectors. This final release came into force on December 29, 2025.
Stakeholders in China will wish to review their chemical inventories in light of these recent actions.
- The updated Emission Standard of Air Pollutants for the Lead and Zinc Industry, effective January 1, 2026, tightening concentration limits for organized (stack) emissions, while also introducing—for the first time—explicit control requirements for fugitive emissions such as leaks, dust, open storage, material handling, and transfer operations.
- Bans beginning on July 1, 2026, on the use of Hydrochlorofluorocarbons (HCFCs) or mixed solvents containing HCFCs as cleaning agents ( Announcement No. 30 of 2025), and the manufacture of extruded polystyrene foam products that use HCFCs, or mixtures containing HCFCs as foaming agents ( Announcement No. 31 of 2025), and
- The release of the List of Priority Controlled Chemicals (Third Batch), adding to the final list with 23 categories of chemical substances, covering carcinogens such as 1,1,2,2-tetrachloroethane and tris(2,3-dibromopropyl) phosphate, as well as endocrine disruptors such as bisphenol A and di(2-ethylhexyl) phthalate (DEHP). These substances are commonly used across many industrial sectors. This final release came into force on December 29, 2025.
Stakeholders in China will wish to review their chemical inventories in light of these recent actions.
New Mandates Under India’s Simplified OSH Code
On November 21, 2025, India’s long-awaited Occupational Safety, Health and Working Conditions (OSH) Code, 2020 , came into force. It replaces 13 National Labour laws with a single consolidated Code that is intended to improve transparency, enhance worker welfare, and promote ease of doing business in India.
Notable changes to improve administrative and compliance provisions include:
- Reducing the need for multiple registrations and licenses to a single license requirement that is valid across India
- Electronic filings – records digitization with the number of registers down from 84 to 8
- 30-day time-bound approval for the site appraisal committee to give its recommendations for an expansion or initial factory location application involving hazardous processes
- Added provisions for third-party audits and certification
- Inspectors will reportedly function more as facilitators rather than enforcers, helping employers with compliance
- A single National OHS Advisory Board replaces six boards to set mandatory national OHS standards for all states.
Worker welfare provisions are also expanded, offering transparency in employment terms, wages, designations, and social security. Key changes include:
- A reduction in the number of required days worked to qualify for annual paid leave
- Specified overtime hours, with workers’ consent,
- Safety Committees, with representatives from employers and workers, are mandated for factories with 500 or more workers, and employers of 250 or more Building & Other Construction Workers (BOCWs),
- Expansion of employee eligibility for a free annual health checkup from seven sectors to all sectors, and
- New provisions to encourage the participation of, and offer safeguards to, women in the workplace.
All employers in India should be aware that the OSH Code, 2020 , is now in force. Any pending revisions to their procedures to meet more stringent requirements and to take advantage of simplified administrative procedures should be implemented as soon as practicable.
On November 21, 2025, India’s long-awaited Occupational Safety, Health and Working Conditions (OSH) Code, 2020 , came into force. It replaces 13 National Labour laws with a single consolidated Code that is intended to improve transparency, enhance worker welfare, and promote ease of doing business in India.
Notable changes to improve administrative and compliance provisions include:
- Reducing the need for multiple registrations and licenses to a single license requirement that is valid across India
- Electronic filings – records digitization with the number of registers down from 84 to 8
- 30-day time-bound approval for the site appraisal committee to give its recommendations for an expansion or initial factory location application involving hazardous processes
- Added provisions for third-party audits and certification
- Inspectors will reportedly function more as facilitators rather than enforcers, helping employers with compliance
- A single National OHS Advisory Board replaces six boards to set mandatory
national OHS standards for all states.
Worker welfare provisions are also expanded, offering transparency in employment terms, wages, designations, and social security. Key changes include:
- A reduction in the number of required days worked to qualify for annual paid leave
- Specified overtime hours, with workers’ consent,
- Safety Committees, with representatives from employers and workers, are mandated for factories with 500 or more workers, and employers of 250 or more Building & Other Construction Workers (BOCWs),
- Expansion of employee eligibility for a free annual health checkup from seven sectors to all sectors, and
- New provisions to encourage the participation of, and offer safeguards to, women in the workplace.
All employers in India should be aware that the OSH Code, 2020 , is now in force. Any pending revisions to their procedures to meet more stringent requirements and to take advantage of simplified administrative procedures should be implemented as soon as practicable.
New AAI Reporting Procedures
New Jersey’s Department of Environmental Protection filed several new actions to its proposed October 2024 contamination and remediation regulations update. An Adopted Partial Rule of October 21, 2025, withdrew the proposal to incorporate licensing board rules and adopted amendments, effective November 17, 2025, to simplify the remedial action permit process and licensing rules, and will promote vapor intrusion action reports in certain permitting. Within the same filing, the Department announced it would re-propose a new section at NJAC 7:26C, because of adverse comments, to establish a spill reporting procedure obligation on persons undertaking all appropriate inquiries (AAI) when they “obtain knowledge that a discharge has occurred at any location on a property.”
These re-proposed rules, filed November 17, 2025, would impose a new obligation to notify the property owner upon obtaining knowledge that a discharge occurred, and nothing else. Instead, a new amendment would obligate remediators to notify the Department of AAI contamination when reported to them by a person undertaking AAI.
New Jersey’s Department of Environmental Protection filed several new actions to its proposed October 2024 contamination and remediation regulations update. An Adopted Partial Rule of October 21, 2025, withdrew the proposal to incorporate licensing board rules and adopted amendments, effective November 17, 2025, to simplify the remedial action permit process and licensing rules, and will promote vapor intrusion action reports in certain permitting. Within the same filing, the because of adverse
comments, to establish a spill reporting procedure obligation on persons undertaking all appropriate inquiries (AAI) when they “obtain knowledge that a discharge has occurred at any location on a property.”
These re-proposed rules, filed November 17, 2025, would impose a new obligation to notify the property owner upon obtaining knowledge that a discharge occurred, and nothing else. Instead, a new amendment would obligate remediators to notify the Department of AAI contamination when reported to them by a person undertaking AAI.