Last updated 6 October 2026
Clause 4.1 of ISO 14001:2026 requires the issues you determine to include environmental conditions that your organisation affects or that can affect it. It now names examples: pollution levels, availability of natural resources, climate change, biodiversity and ecosystem health. The separate 2024 sentence on climate change has gone. Climate change is now one condition inside a wider test that runs in both directions.
When the dams that supply Nelson Mandela Bay ran low, I visited a food plant there whose context register said, in one line, that climate change was relevant and low risk. That same month the engineers were installing water storage tanks and re-planning cleaning cycles around restrictions. The register said one thing. The site was living another. The 2026 wording of clause 4.1 is written to close exactly that gap.
Transition to ISO 14001:2026 builds environmental conditions in 4.1 in module 2, beyond the climate change sentence, and carries the result into 4.2, 6.1.2 and 6.1.4. You finish with a delta check, an evidence position on every change, a dated action plan and a readiness score. About 8 hours online, R1 950.
What does clause 4.1 of ISO 14001:2026 require?
You still determine the external and internal issues that affect your ability to achieve the intended outcomes of the EMS. Those issues must include environmental conditions, in both directions, and the standard now names five examples.
Think of it as two questions. Which conditions does the site change? Your trade effluent to the municipal sewer, the stream along the back fence, the borehole you draw from, the air around your boiler stack. And which conditions can change the site? Drought, floods, heat waves, upstream pollution, a shortage of packaging timber.
Annex A.4.1 adds useful guidance. Conditions can be local or global, sudden or gradual, and they connect to each other. Climate interacts with water availability, which interacts with ecosystem health. The annex also lists air quality, water quality, land use and existing contamination as conditions worth considering. No documented information is specified for 4.1, but an auditor will still want to see how you reached your answer.
How is this different from the 2024 climate change amendment?
Amendment 1:2024 added a sentence asking you to determine whether climate change is a relevant issue. The 2026 edition drops that standalone sentence and lists climate change as one named environmental condition among five.
| Point | ISO 14001:2015 with Amd 1:2024 | ISO 14001:2026 |
|---|---|---|
| Climate change | Standalone sentence: decide whether it is a relevant issue | One named example of an environmental condition |
| Other conditions | Issues include environmental conditions, but no examples in the requirement | Pollution levels, natural resources, climate change, biodiversity and ecosystem health named |
| Interested parties (4.2) | Note that parties can have climate change requirements | NOTE 1 widened to all environmental conditions |
| Annex A guidance | Shorter | A.4.1 expanded: local to global, sudden or gradual, interconnected, ecosystem health explained |
If you added a climate change line in 2024, keep it. It is not wrong. It is incomplete. The real build is the other four named conditions, tested against your own site, and the trail from each relevant one into the rest of the system.
What counts as an environmental condition on a food site?
Any state of the environment around you that your operation changes, or that can change your operation. On South African food sites, water, heat and the receiving environment usually come first.
| Condition | How the site affects it | How it affects the site |
|---|---|---|
| Water availability (ready meals plant) | Draws municipal water for cleaning and cooking | Restrictions and drought cut production and cleaning time |
| Water quality (citrus packhouse) | Fungicide drench and wax line wash water can reach soil and groundwater | Borehole quality affects drench mixing and washing |
| Climate change and heat (restaurant group) | Refrigerant leaks and generator diesel add emissions | Hotter summers work cold rooms harder and raise breakdown risk |
| Ecosystem health (ready meals plant) | Stormwater outlet discharges to a stream along the fence | A degraded stream draws community and regulator attention |
| Natural resources (packhouse) | Cartons and pallets use paper and timber | Supply and price of packaging material |
| Pollution levels (any industrial park) | Boiler and generator emissions | Neighbours’ emissions or contaminated land on a shared site |
Do not stop at the table. Some conditions will be not relevant for your site, and that is a legitimate answer if you can say why.
Where does climate change show up after clause 4.1?
It runs through 4.2, 5.2, 6.1.2, 6.1.4 and 9.3. Clause 4.1 is the start of a chain, not a box to tick on its own.
- 4.2 NOTE 1: interested parties can have needs about environmental conditions. A retailer’s questionnaire on water or emissions is one.
- 5.2 c) NOTE: specific policy commitments can include climate change mitigation and adaptation, protection of biodiversity and ecosystems, and conservation of natural resources.
- 6.1.2: Annex A.6.1.2 treats adverse environmental conditions that increase emissions as abnormal conditions, and lets environmental conditions inform significance.
- 6.1.4: risks and opportunities must address undesired effects, including external environmental conditions affecting the organisation. Annex A.6.1.4 gives flooding, drought, extreme temperatures, wildfires and water scarcity as examples.
- 9.3.2 b) 1): changes in external and internal issues are a management review input.
The new risks and opportunities sub-clause is where most of the 4.1 work lands. I cover the full list of what moved in ISO 14001:2026 vs 2015: every change.
Stop guessing which conditions your auditor will expect. See the Transition to ISO 14001:2026 course: builds for 4.1 and the new 6.1.4 register, and scenario checks marked the moment you submit. About 8 hours, R1 950.
Does ISO 14001:2026 require a carbon footprint?
No. There is no clause requiring a greenhouse gas inventory, a carbon footprint or a net zero target. A legal or customer reporting duty becomes a compliance obligation through 4.2 and 6.1.3, and that is where it is managed.
In South Africa the relevant laws include the Climate Change Act 22 of 2024, the Carbon Tax Act 15 of 2019 and the National Greenhouse Gas Emission Reporting Regulations. Whether any of them apply depends on your activities. If they apply, they belong in the compliance obligations register. If they do not, record why. Building that register properly is covered in the ISO 14001 legal register for South Africa.
The 2026 bibliography lists ISO 14090 and ISO 14091 for climate adaptation. They are useful reading for a larger site. They are not requirements of ISO 14001.
What will the auditor ask about clause 4.1?
Expect to be asked where environmental conditions sit in your context, how you decided which matter and where each relevant one went next.
- Show me where climate change, water and biodiversity were considered. Why is this one marked not relevant?
- You draw borehole water. Where is resource availability in your issues?
- This condition is marked relevant. Which risk or opportunity under 6.1.4 came from it?
- When did management review last look at changes in these issues?
The weak answer is a page copied from the internet about global warming. The strong answer is six short lines about your own site, each traced forward.
Not sure if your context register will survive a 2026 audit? WhatsApp ASC on +27 61 483 0381.
How do you update your context analysis for 2026?
Test each named condition in both directions against your own site, record the decision, and carry the relevant ones forward.
- List the five named conditions, plus any from Annex A.4.1 that fit your site, such as air quality, water quality, land use or existing contamination.
- For each, write how the site affects it and how it affects the site. Use site data: water meter readings, effluent results, incident logs, weather events.
- Walk the boundary: stormwater outlets, drains, the nearest watercourse, the neighbours.
- Mark each condition relevant or not relevant, with a one line reason.
- Check 4.2 for interested party expectations on the relevant conditions.
- Carry relevant conditions into 6.1.2 (abnormal conditions, significance) and 6.1.4 (risks and opportunities).
- Check your 5.2 policy commitments still fit.
- Put changes in these issues on the management review agenda.
If your team still mixes up aspects, impacts and conditions, send them to environmental aspects and impacts explained first.
Frequently asked questions
What does ISO 14001:2026 clause 4.1 say about climate change?
Clause 4.1 lists climate change as one example of an environmental condition that the organisation affects or that can affect it. The other named examples are pollution levels, availability of natural resources, biodiversity and ecosystem health.
Is the ISO 14001 climate change amendment still in force?
ISO 14001:2026 cancels and replaces both ISO 14001:2015 and Amendment 1:2024. The intent of the amendment continues in the wider environmental conditions requirement of clause 4.1.
Does clause 4.1 require documented information?
No documented information is specified for 4.1. Auditors still expect to see how issues and environmental conditions were determined, so most sites keep an issues register.
Do I need a separate climate risk assessment for ISO 14001:2026?
No separate document is required. Climate related risks and opportunities are determined under 6.1.4 with your other risks and opportunities, using a method you choose.
Can climate change be marked not relevant?
Yes, if you can justify it for your site. An auditor will test the reason, so base it on site facts such as water supply, heat exposure and flood risk.
Does ISO 14001:2026 require greenhouse gas reporting?
No. Reporting duties come from law, such as the Climate Change Act 22 of 2024 where it applies, or from customers, and are managed as compliance obligations.
Which ASC course covers environmental conditions and the rest of the transition?
Transition to ISO 14001:2026 treats clause 4.1 as the first build and follows it through interested parties, aspects, the new risks and opportunities register, planning of changes and management review. It is written for sites that already hold a 2015 certificate.
R1 950, the full course price. No VAT is charged, so the price shown is the price paid. Teams of five or more: contact ASC for a team rate.
- 4 modules, 22 lessons, about 8 hours, self paced on phone or laptop
- Module 2 builds environmental conditions in 4.1, beyond the climate change sentence
- Builds for 4.2, 4.3, 6.1.2, 6.1.4, 6.3, 8.1 and 9.2.2 across the course
- Scenario checks, case study assessments and a game between modules, all marked automatically
- Case sites Mzansi Fresh Meals, Sundays Valley Citrus and Ubuntu Grill Group (training scenarios built from real audit patterns), or your own site
- ASC certificate of completion with a verification code an employer can check
- Is it for me? Yes, if you are moving a certified ISO 14001:2015 system and own the context, risk or audit work.
- How long does it take? About 8 hours. Each lesson is short enough for a lunch break.
- Will it work at my site? Yes. You test the named conditions against your own site data, or a case site if you prefer.
Building the whole system for the first time? Take ISO 14001:2026 Understanding and Implementation (R4 800), which builds a context and environmental conditions register from scratch. For a plain words overview, start with Introduction to ISO 14001:2026 (R1 495). All the options are on the ASC ISO 14001 training page.
ISO 14001 is copyright and is not reproduced here. ASC is not affiliated with ISO.
Sources
- ISO 14001:2026, Environmental management systems, ISO
- ISO 14001:2015/Amd 1:2024, Climate action changes, ISO
- Climate Change Act 22 of 2024
- Carbon Tax Act 15 of 2019
- ISO 14090, Adaptation to climate change: Principles, requirements and guidelines, ISO