ISO 14001:2026 carries an explicit compliance obligations clause at 6.1.3 and an explicit evaluation of compliance clause at 9.1.2. It asks the organization to determine the obligations attaching to its environmental aspects, evaluate whether it is meeting them at a determined frequency, and maintain a current understanding of its compliance status.
ISO 9001:2015 has neither clause. It carries statutory and regulatory requirements in seven places, and in every one of them they are requirements for the product or the service — determined at 8.2.2 d), reviewed before commitment at 8.2.3.1, taken as design inputs at 8.3.3 c), passed to external providers at 8.4.2, and considered for post-delivery at 8.5.5 a). There is no register, no applicability determination, no evaluation frequency and no compliance status anywhere in the standard.
| ISO 9001:2015 asks | ISO 14001:2026 asks | |
|---|---|---|
| The question | Is what we supply lawful in the market it goes to? | Is what we do lawful where we do it? |
| The subject | The product or service | The organization and its environmental aspects |
| Where it is determined | 8.2.2 d), as a requirement for the product | 6.1.3 a), as an obligation of the organization |
| Where it is checked | 8.2.3.1, before committing to supply | 9.1.2, at a determined frequency, continuously |
| Register required? | No | Yes — documented information under 6.1.3 |
| Evaluation frequency? | No | Yes — determined under 9.1.2 a) |
| Compliance status? | No | Yes — maintained under 9.1.2 c) |
Reading the right-hand column as the whole job is the most common mistake in a combined system, and reading the left-hand column as covered by it is the second. An organization with an excellent environmental compliance register can still ship a product into a market whose substance restrictions it never determined — and an organization with rigorous requirements review can still be operating a site outside its permit conditions.
Quality and environmental managers running ISO 9001 and ISO 14001 together, particularly where the organization exports. The exposure this closes is the obligation that sits between the two systems: a substance restriction held as a customer requirement in the quality system and absent from the environmental register, or a permit condition on a material nobody connected to the product it goes into.
ISO 9001 tests a product obligation once, at requirements review, before commitment. That is a moment, not a cycle. This procedure sets a frequency and a method for product obligations as well, plus a standing rule that re-evaluates every one of them on any change of material, component, supplier or formulation — regardless of when it was last checked. That rule is the only reliable control against a compliant product quietly becoming a non-compliant one.
The same product carries different duties depending on whether you are the manufacturer, importer, distributor or own-brand labeler in that market. Organizations that have always manufactured domestically and start exporting are frequently the importer of record without having decided to be. It is a register field and a written determination per market.
Once product has left the building, a compliance failure becomes a question about goods already in the market. Withdrawal, recall, notification to a market authority, informing distributors — all run on timescales set by the destination market rather than by your corrective action process. The template makes the product-in-market determination a same-day step alongside the notification decision.
Ten divergences, each with what this procedure does, the alternative that was available, and a place to confirm, followed by eight decisions to sign off before adoption. These are differences of kind rather than of depth: almost every one is a mechanism ISO 14001 provides that ISO 9001 does not have at all.
| # | Where the two standards differ |
|---|---|
| H-1 | ISO 14001 requires the obligations as documented information. ISO 9001 requires no register of any kind |
| H-2 | ISO 14001 requires the evaluation frequency to be determined. ISO 9001 requires no interval |
| H-3 | ISO 14001 requires compliance status to be maintained. ISO 9001 has no equivalent |
| H-4 | ISO 14001 requires evidence of evaluation results. ISO 9001 8.2.3.2 requires records of the review — a different record about a different event |
| H-5 | ISO 14001 requires a determination of how obligations apply. ISO 9001 requires requirements to be determined but not how they apply |
| H-6 | ISO 14001 supplies register, frequency, evaluation and status. ISO 9001 supplies none of them. The largest decision in the appendix |
| H-7 | ISO 14001 attaches obligations to environmental aspects. ISO 9001 attaches them to products and services |
| H-8 | ISO 9001 8.3.3 c) requires statutory and regulatory requirements as design inputs. ISO 14001 has no design clause |
| H-9 | ISO 9001 8.5.5 a) requires them to be considered in post-delivery activity. ISO 14001 has no equivalent |
| H-10 | Only the product scope carries a duty about goods already supplied |
45 pages, 48 tables, every bracketed placeholder a decision you make rather than a blank someone forgot.
| What | How much of it |
|---|---|
| Numbered sections | 18 — 0.0 Document Control through 17.0 Revision History |
| Appendices | 6 — A, B, C, D, E and F |
| Integration decision record | 10 divergences, each with the alternative and a place to confirm |
| Trigger table | 14 named triggers, each with the scope, the role that raises it and a time limit |
| Responsibilities | 7 roles, each gating role with a named alternate |
| Procedure steps | 12 numbered steps, 7.1 through 7.12 |
| Evaluation methods | 8 methods, each with what it suits and the evidence the record must name |
| Exception paths | 9 cases, each with what happens and an owner |
| Records table | 14 records, each with owning role and retention period |
| Process interfaces | 11 interfaces, what flows in and what flows out |
| Key performance indicators | 8 indicators with target and owner |
| Maturity ladder | 8 elements, 4 levels each, described as observable behavior |
| Clause cross-reference | 32 rows, every obligation mapped to every standard |
| Compliance obligations register | 31 fields, ready to use as a spreadsheet |
| Compliance evaluation record | 17 fields |
| Nonfulfillment action record | 18 fields |
| Worked examples | 2, deliberately different in shape |
| Auditor questions answered | 13, each with where in the document the answer is |
| Determination worksheet | 5 parts, to be completed before the procedure runs |
| Process interaction map | Included — required by ISO 9001 Clause 4.4.1 |
Every procedure Management Systems International publishes is built to seven structural marks. Most procedures in circulation satisfy four or five, and the ones they miss are almost always the same ones.
Worked example one: the shared input. A solvent-based coating carrying a permit emission condition and a restricted-substance limit in two of five markets. The supplier reformulates to improve drying time; the change is assessed for product performance and approved. Nobody assesses it against either duty. The environmental register had no link to the material; the quality change control asked whether the product still met specification, and it did. Each function did its job correctly.
Worked example two: the market nobody assessed. The same product, unchanged, into two new countries. No design change, no aspect change, nothing either management system was watching for. It engaged a producer registration deadline, a packaging recovery obligation, a marking requirement, and a take-back duty — and in one market made the organization the manufacturer placing on the market rather than the distributor’s supplier.
Single-standard variants of this procedure are published for ISO 14001:2026, ISO 45001:2018 and ISO 7101:2023. Combined variants cover ISO 14001 with ISO 45001, and an integrated variant covers all three of ISO 9001, ISO 14001 and ISO 45001.
No. ISO 9001:2015 carries statutory and regulatory requirements in seven clauses — 1 a), 4.2, 5.1.2 a), 8.2.2 d), 8.2.3.1, 8.4.2 c) 1) and 8.5.5 a), plus 8.3.3 c) as a design input — and in every one of them they are requirements for the product or the service. There is no register, no applicability determination, no evaluation frequency and no compliance status anywhere in the standard.
ISO 14001 supplies the machinery: a register, an applicability determination, a determined evaluation frequency, and a compliance status held continuously. The combined variant applies that machinery to product compliance obligations as well, and records the decision to do so. Appendix D sets out all ten points where the two standards diverge, what this procedure does about each, and the alternative that was available.
A single duty attaching in both scopes. A substance restriction limits what may be placed on the market and what may be used or discharged on site. Recorded in two places by two functions, it is evaluated twice and owned by neither. One register makes it one row with two marks and a single owner.
It satisfies ISO 9001 8.2.3.1, which is a review before commitment. It does not tell you whether the obligation is still met eighteen months later when the supplier has reformulated a component and the drawing did not change. The template carries a standing rule that re-evaluates every product obligation on any change of material, component, supplier or formulation, regardless of when it was last checked.
Everything, if you export. The same product carries different duties depending on whether you are the manufacturer, the importer, the distributor or the own-brand labeler in that market, and organizations routinely assume they are the lightest of the four. It is a field on every product register row and a determination made in writing per market.
Yes, and it treats them differently because they are different. Environmental obligations follow the site; product obligations follow the product into its destination market. Jurisdiction, site, product and market are all register fields, and both a new site and a new market are triggers assessed before work or supply begins.
No. Clause 9.2 asks whether the management system conforms to your own requirements and to the standard and is effectively implemented. Clause 9.1.2 asks whether you are meeting your compliance obligations. They can be scheduled together but they produce separate results and separate evidence.
Yes. ISO 9001 Clause 4.4.1 requires the organization to determine the processes needed and their sequence and interaction; ISO 14001 has no equivalent requirement. The map is included along with the full interface table it depicts.
The 2026 edition, published April 15, 2026. Appendix F covers the transition and flags the cross-reference that breaks most transitioned documents: risks and opportunities moved from 6.1.1 to 6.1.4 and planning action to 6.1.5. In an integrated document that is worse than in a single-standard one, because the same subject sits at a different number in each standard.
Editable Microsoft Word (.docx). Purchase grants your organization a perpetual, non-exclusive license to edit, rebrand and adopt it, including at multiple sites under common ownership. It may not be resold or distributed outside your organization.
Building the quality side of this? The QMS Interviews course covers how to get accurate answers out of the people who actually run the process.
Already certified to ISO 14001:2015? The ISO 14001:2026 Transition course walks the changes clause by clause. Relevant only if you hold a current 2015 certificate.
Not sure where your process actually sits? Take the free Compliance Evaluation Maturity Check at msi-international.com. Eight elements, under five minutes, score shown immediately.
Want help implementing it? Call Management Systems International at 760-434-9141 to schedule a planning session.
Management Systems International is a veteran-owned, female-owned ISO consulting firm founded in 1998. Across 28 years we have supported 80+ certifications, attended 200+ audits alongside our clients, and trained 600+ professionals across manufacturing, technology, medical device, government, healthcare, and other regulated industries.
We write these templates the way we write procedures for clients: as finished, worked documents with the judgment calls already made and explained, so you can see what a decided position looks like before you make your own.
Perennia Corp is a fictional company used for illustration throughout the template, and is not connected with any real organization of the same or a similar name. This is a template and guide, not certification or legal advice. Your compliance obligations are yours to determine, and unfilled placeholders are unmet requirements.
ISO 9001 and ISO 14001 are trademarks of the International Organization for Standardization. This template is an independent work by Management Systems International, LLC and is not endorsed by or affiliated with ISO or any certification body. None of the standards is reproduced in the template.
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