Last updated 6 October 2026
An ISO 14001 legal register in South Africa is the compliance obligations register that clause 6.1.3 requires: every Act, regulation, permit, licence, by-law and adopted customer requirement linked to your environmental aspects, with a note of how each applies to your site. Clause 9.1.2 then requires you to evaluate compliance at a frequency you set and keep the results as evidence.
Two weeks before an export season, I sat in the boardroom of a citrus packhouse with their legal register: forty pages of Act titles printed from a subscription service. Not one line named a borehole, a permit number or a waste stream. The packhouse manager asked if it was enough. I asked him where the borehole authorisation was. Nobody knew.
Get it right once with ISO 14001:2026 Understanding and Implementation. You build your own compliance obligations register tied to NEMA, the Waste Act, the Air Quality Act, the National Water Act, the Climate Change Act and municipal by-laws, plus the compliance evaluation that keeps it honest. About 24 hours, self paced, R4 800.
What does ISO 14001 clause 6.1.3 require?
Three things: determine and have access to the compliance obligations related to your aspects, determine how they apply to your organisation, and take them into account across the system. The obligations themselves must be available as documented information.
The standard never says “legal register”. It says compliance obligations, which is wider. Annex A.6.1.3 lists the mandatory sources: requirements from government authorities, laws and regulations, permits and licences, orders from regulators, and court or tribunal judgments. It also lists voluntary sources, such as agreements with community groups, customers or authorities, industry standards, labelling schemes and contracts. Under 4.2 NOTE 2, a customer requirement becomes a compliance obligation the moment you decide to comply with it.
Clause 6.1.3 did not change in substance in the 2026 edition. What changed around it is that 4.2 c) now asks which interested party requirements will be addressed through the system, and 6.1.4 treats compliance obligations as a source of risks and opportunities.
Which South African laws belong on a food site’s register?
Most food and agri sites need lines from NEMA, the Waste Act, the Air Quality Act, the National Water Act and municipal by-laws, with the Climate Change Act, carbon tax and OHS Act regulations where the activities trigger them. Which sections apply depends on your aspects, not on a generic list.
| Law | Typical trigger on a food or agri site | What the register line must show |
|---|---|---|
| National Environmental Management Act 107 of 1998 | Any activity that can pollute or degrade (section 28 duty of care), any spill or release (section 30 emergency incidents), new developments (section 24 authorisations) | The aspects it covers, the incident reporting contacts, any environmental authorisation and its conditions |
| National Environmental Management: Waste Act 59 of 2008 | General and hazardous waste, storage areas, contractors | Classification under GN R.634 of 2013, storage against GN R.926 of 2013, licensed contractors, safe disposal certificates, any EPR duty |
| National Environmental Management: Air Quality Act 39 of 2004 | Boilers and other combustion plant | Whether the activity is listed and needs an Atmospheric Emission Licence, whether the boiler is a declared controlled emitter under the national small boiler emission standards, or whether only the municipal air quality by-law applies |
| National Water Act 36 of 1998 | Boreholes, river abstraction, effluent ponds, irrigation with wastewater | The section 21 water uses and the licence, general authorisation or registration for each, plus pollution duties in sections 19 and 20 |
| Municipal by-laws | Trade effluent to sewer, air quality, waste | Permit number, the actual limits, sampling points and reporting dates |
| Climate Change Act 22 of 2024, Carbon Tax Act 15 of 2019, National Greenhouse Gas Emission Reporting Regulations | Fuel combustion, refrigerants, larger emitters | Whether a duty applies today, and who watches for new regulations |
| Occupational Health and Safety Act 85 of 1993 | Ammonia refrigeration, hazardous chemicals | Overlap with Major Hazard Installation Regulations 2022 and Hazardous Chemical Agents Regulations 2021 where they apply |
For a plain overview of what each Act is for, read the South African environmental laws behind ISO 14001. This article is about turning those Acts into register lines.
How do you build the compliance obligations register, step by step?
Start from your aspects register, not from a list of Acts. For each aspect, find the obligations that govern it, translate them into what your site must actually do, and give each line an owner, evidence and an evaluation frequency.
- Take the aspects register as your index. Every aspect, significant or not, is a question: which law, permit or agreement covers this?
- Collect your own documents first. Permits, licences, authorisations, registrations, municipal letters, regulator directives and customer contracts. These are documented information of external origin and need control under 7.5.3.
- Find the governing provisions. Act and section, regulation and number, by-law and clause. Use a legal update service as a source if you like, but check every line against your activities.
- Write how it applies. This is 6.1.3 b), and it is where most registers fail. “Comply with the trade effluent by-law” is useless. “COD and pH within the limits in permit conditions, sampled at the final manhole, results to the municipality monthly” is a register line.
- Add the voluntary obligations you have adopted. A retailer’s supplier code, an export customer’s environmental requirement, a commitment to a neighbouring farm.
- Assign an owner, the evidence and a frequency. Who keeps it current, what proves compliance, and how often you will check.
- Set up the update route. New regulations, permit renewals and new customer requirements are changes. Route them through your planning of changes under 6.3 so the aspects, controls and training move with them.
What does a good register line look like?
One aspect, one obligation, a site-specific requirement, an owner, the evidence and the next evaluation date. Here are four lines for Sundays Valley Citrus, the packhouse case site in our course, which is a training scenario built from real audit patterns.
| Aspect | Obligation | How it applies here | Evidence |
|---|---|---|---|
| Borehole abstraction | National Water Act 36 of 1998, section 21 water use | Abstraction must be authorised by licence, general authorisation or lawful existing use, within the volume allowed | Authorisation document, monthly meter readings against the allowed volume |
| Spent fungicide drench to the evaporation pond | National Water Act 36 of 1998, sections 19 and 21, NEMA section 28 | Disposal must be authorised and must not pollute groundwater or the river | Authorisation or legal opinion, pond inspection records, freeboard checks |
| Used oil and empty fungicide containers | Waste Act 59 of 2008, GN R.634 and GN R.926 of 2013 | Classify, store in a compliant area, use a licensed contractor | Classification, store inspection, waste manifests, safe disposal certificates |
| Packaging to the export customer | Customer environmental requirement adopted under 4.2 c) | The requirements written into the supply agreement | Signed agreement, packaging specifications |
The borehole line is where the packhouse in my story came unstuck. It turned out to be a lawful existing use that had never been verified. That took months to sort out. A list of Act titles would never have shown the gap.
Turn your own permits into register lines like these, with model answers to check against. Enrol in ISO 14001:2026 Understanding and Implementation: about 24 hours, scenario checks marked automatically the moment you submit, R4 800 with no VAT added.
How do you evaluate compliance under clause 9.1.2?
Set a frequency for each obligation, evaluate it against evidence, act where you fall short, and keep the results as evidence. Clause 9.1.2 also asks you to maintain knowledge and understanding of your compliance status, so you should know where you stand between evaluations as well as on evaluation day.
Annex A.9.1.2 allows the frequency to vary by obligation, as long as every obligation is evaluated periodically. It also lets you use evaluations done by others, such as a municipal inspection report. Here is how I usually set it on a food site:
| Obligation type | Frequency I usually set | Evidence |
|---|---|---|
| Permit limits with sampling (trade effluent, emissions) | Monthly, as results arrive | Lab results against each limit, trend |
| Waste storage and contractor licences | Quarterly | Store inspection, contractor licence check, manifests |
| Water use authorisations and volumes | Quarterly and at season end | Meter readings against allowed volume |
| General duties, reporting and voluntary obligations | Annually, before management review | Signed evaluation with findings and actions |
One point people miss. Annex A.9.1.2 says a non-compliance that your system finds and corrects is not automatically a nonconformity. A system that never finds anything, though, is not looking. When a limit is exceeded, record it, correct it, report it if the permit requires, and run it through 10.2.
What do auditors find wrong with legal registers?
Act titles with no application, missing permits, voluntary obligations nobody wrote down, and compliance evaluations that consist of a signature with no evidence behind it.
An auditor will take a register line and ask to see the permit, then the latest results against its limits, then the person who keeps it. If any link breaks, expect a finding against 6.1.3 or 9.1.2. The audit side of this is covered in auditing compliance obligations, and the ISO 14001:2026 Internal Auditor course (limited period special, R3 850) trains you to test it.
Pressure from a retailer questionnaire, or a municipality asking for your effluent results? Not sure which ISO 14001 course fits your job? WhatsApp ASC on +27 61 483 0381. The full set of courses sits on the ISO 14001 training hub.
Frequently asked questions
Is a legal register required by ISO 14001?
ISO 14001 does not use the words legal register. Clause 6.1.3 requires compliance obligations to be available as documented information, and most sites meet that with a register that also shows how each obligation applies to them.
What is the difference between a legal requirement and a compliance obligation?
Compliance obligations include legal requirements and other requirements that the organisation has to comply with or chooses to comply with. A customer or community requirement becomes a compliance obligation once you decide to comply with it.
How often must compliance be evaluated under ISO 14001?
You set the frequency under clause 9.1.2 a), and Annex A.9.1.2 allows it to vary by obligation. Every obligation must be evaluated periodically, and the results must be available as evidence.
Is a legal non-compliance automatically an ISO 14001 nonconformity?
Not automatically. Annex A.9.1.2 says a non-compliance identified and corrected through the EMS processes need not be a nonconformity, but it must still be corrected and recorded.
Can I buy a ready-made ISO 14001 legal register for South Africa?
A purchased list can help you find sources, but it cannot show how each obligation applies to your own aspects, which clause 6.1.3 b) requires. You still have to tie every line to your own permits, limits and activities.
Which South African laws cover environmental incidents?
Section 30 of the National Environmental Management Act 107 of 1998 covers the control of emergency incidents, and section 20 of the National Water Act 36 of 1998 covers emergency incidents affecting water resources. Both usually belong on a food site’s register.
Which ASC course builds the compliance obligations register with you?
ISO 14001:2026 Understanding and Implementation ties every requirement of the standard to South African law and walks you through building a compliance obligations register that names your permits, your limits and your evidence. Then it sets up the compliance evaluation that proves it to an auditor, a retailer or a municipal inspector.
R4 800 for the course. No VAT is charged, so the price shown is the price paid. Teams of five or more: contact ASC for a team rate.
- Covers NEMA, the Waste Act, Air Quality Act, National Water Act, Climate Change Act and municipal by-laws
- Builds your compliance obligations register, aspects register, and risk and opportunity register
- Module 5 covers monitoring, compliance evaluation, internal audit and management review
- 6 modules, 67 lessons and workshop sittings, about 24 hours, on phone or laptop
- Scenario checks, case studies and games, marked automatically with feedback that names the lesson to revisit
- ASC certificate of completion naming the course, code and date, with a verification code
- Is it for me? Yes if you keep the legal register, sign the compliance evaluation, or answer to the municipality for the effluent.
- How long does it take? About 24 hours, self paced. Stop when the plant needs you and pick up where you left off.
- Will it work at my site? Yes. Use your own permits, or practise on a packhouse, a ready meals plant or a restaurant group.
Staff who only need to know the laws behind their jobs can take Introduction to ISO 14001:2026 (R1 495). Sites with a 2015 certificate should look at Transition to ISO 14001:2026 (R1 950).
ISO 14001 is copyright and is not reproduced here. ASC is not affiliated with ISO.
Sources
- ISO 14001:2026, Environmental management systems, ISO
- National Environmental Management Act 107 of 1998
- National Environmental Management: Waste Act 59 of 2008
- National Water Act 36 of 1998
- National Environmental Management: Air Quality Act 39 of 2004
- Climate Change Act 22 of 2024