Last updated 6 October 2026
Clause 6.3 Planning of changes is new in ISO 14001:2026. When you decide a change is needed that affects or can affect your environmental management system, you must carry it out in a planned way and manage it so the system still achieves its intended outcomes. No documented information is specified, but auditors will look for evidence that changes were planned before they happened.
A citrus packhouse switches post-harvest fungicide because an export market tightened its residue limits. Procurement orders the new product, the drench line is reset over a weekend and the spent solution goes to the same disposal route as before. Nobody asks whether the waste classification changed, whether the contractor who removes it knows, or whether the aspects register still describes reality. Under the 2015 edition people would argue about which clause that broke. Under 2026 the answer is 6.3.
Transition to ISO 14001:2026 covers planning of changes as one of the module 2 builds and shows how 6.3 links to 6.1.2, 8.1 and 9.2.2. You leave with a delta check of your system, an evidence position on every change, a dated action plan and a readiness score. About 8 hours online for R1 950.
What does clause 6.3 require?
Two things. Carry out changes that affect the EMS in a planned manner, and manage them so the system still achieves its intended outcomes: better environmental performance, meeting compliance obligations and achieving environmental objectives.
The clause has two notes. The first says the need for change can come from inside or outside the organisation and points to examples in Annex A.6.3. The second says managing change already appears in several other requirements. The clause is short. Its reach is long, because almost every decision a site makes touches at least one aspect, one obligation or one contractor.
Why add 6.3 when 8.1 already covered planned changes?
Clause 8.1 controls planned changes to operations and reviews unintended ones. Clause 6.3 works at system level: changes that touch the EMS itself, its scope, registers, roles, providers and audits.
Annex A.6.3 lists the clauses that already carry change requirements. Clause 6.3 ties them together so a change is planned once, not discovered six times.
| Clause | What it asks about change |
|---|---|
| 6.1.2 b) | Take change into account when determining aspects, including planned or new developments and new or modified activities, products and services |
| 7.4.2 a) | Communicate changes to the EMS internally, as appropriate |
| 7.5.3 | Control changes to documented information, for example version control |
| 8.1 | Control planned changes and review the consequences of unintended changes |
| 9.2.2 | Consider changes affecting the organisation when establishing the audit programme |
| 10.2 e) | Make changes to the EMS, if necessary, after a nonconformity |
Which changes does clause 6.3 cover?
Any change that affects or can affect the EMS, whether you choose it or it is forced on you. Annex A.6.3 gives examples from new equipment to supply chain disruption, and asks you to review unintended changes too.
| Type of change | Example on a food site |
|---|---|
| New or changed products, processes, equipment or facilities | A new fryer line, a second boiler, a new cold store |
| Changes to compliance obligations | A revised trade effluent by-law limit, new packaging duties under the EPR regulations |
| New knowledge about aspects, impacts, risks or opportunities | Effluent results showing a parameter close to the permit limit |
| Technology | Replacing a diesel generator with solar and battery storage |
| Material specifications | A new fungicide, cleaning chemical or refrigerant |
| Mergers and acquisitions | Buying a second packhouse or taking over franchise stores |
| Staff or external provider changes | A new waste contractor, or losing the only person trained on the effluent plant |
| Business disruption | Supply chain failure, labour disputes, floods or unrest |
Unplanned changes count. When a flood closes the road and hazardous waste sits on site for a week, the system changed whether you planned it or not.
What do auditors ask for under clause 6.3?
They pick a real change from the last year and trace it. Was the environmental effect assessed before go-live, were the registers updated, were people told, and did the system still deliver its intended outcomes?
My own opening question at a transition audit is simple: what has changed on site since the last visit? Then I go looking for the answer in the capex list, purchase orders for new chemicals, the contractor list, the organogram, the maintenance log and the management review minutes. The changes I find there and not in your change records are the findings.
- A record that the change was considered before it happened: a form, minutes, or an email trail with a decision
- The aspects register updated where aspects changed (6.1.2)
- Compliance obligations checked: permit, licence, by-law (6.1.3)
- Risks and opportunities considered (6.1.4)
- Documents, training and contractor briefings updated (7.5.3, 7.2, 8.1)
- A check after go-live that the intended outcomes held
Get 6.3 right before the auditor tests it. Enrol in Transition to ISO 14001:2026 for R1 950 and work through planning of changes, externally provided processes and the audit programme in about 8 hours, at your own pace.
Do you need a management of change procedure?
The standard does not require one. You need a way of working that produces evidence. On most certified food sites that means adding environmental questions to an existing change form, not writing a new procedure.
Most food plants already have a change route for food safety and, where they hold ISO 45001, for health and safety. Add an environmental section to that form with six questions. Does the change create or alter an aspect? Does it touch a permit, licence or by-law? Does it change waste, effluent or emissions? Does it bring in or change a contractor or supplier? Does it change an emergency scenario? Who needs training or a briefing? One form, three systems, one signature trail.
Internal auditors should test 6.3 by tracing, not by reading the procedure. The ISO 14001:2026 Internal Auditor course covers auditing each clause, including 6.2 and 6.3, and it is R3 850 on a limited period special.
Not sure which ISO 14001 course fits your job? WhatsApp ASC on +27 61 483 0381.
How do you take a change through the EMS?
Use the same eight steps for a new chemical, a new contractor or a new store. Small changes move through quickly. Big ones get the attention they need.
- Capture the change early: what it is, who proposes it and when it is planned.
- Screen it. Does it affect aspects, compliance obligations, risks and opportunities, objectives, emergency scenarios or external providers? If none, record that and close.
- Assess it. Update the aspects register and significance (6.1.2), check compliance obligations (6.1.3) and update risks and opportunities (6.1.4).
- Plan it: actions, resources, responsibilities and timing.
- Prepare people and documents: training, awareness, document versions and contractor requirements (7.2, 7.3, 7.5.3, 8.1).
- Approve and implement.
- Check after go-live: monitoring results, an inspection, confirmation that outcomes held.
- Feed it back: report it to management review and let the audit programme consider it (9.2.2).
On the packhouse in the opening, step 2 would have caught the fungicide change in ten minutes. The full list of 2026 changes, of which 6.3 is one, is in ISO 14001:2026 vs 2015: every change.
How does 6.3 fit with ISO 45001 and ISO 22000 on one site?
Run one change process. ISO 9001:2015 and ISO 22000:2018 already have a clause 6.3 on planning of changes, and ISO 45001:2018 has management of change in 8.1.3. ISO 14001 now lines up with them.
The risk on an integrated site is that environmental questions get lost on a form built for food safety. Give the environment its own section and its own sign-off. When auditors run a combined audit they can trace the same change through all the systems at once. That approach is covered in combined audits with ISO 9001, ISO 45001 and FSSC 22000.
Frequently asked questions
Is planning of changes new in ISO 14001:2026?
Yes. Clause 6.3 Planning of changes did not exist in ISO 14001:2015. It brings ISO 14001 into line with the harmonized structure used by other ISO management system standards.
Does clause 6.3 require a documented procedure?
No documented information is specified in 6.3. Auditors will still ask for evidence that changes affecting the system were planned, so most sites keep change records.
What is the difference between clause 6.3 and the changes in clause 8.1?
Clause 8.1 controls planned changes to operations and reviews unintended ones. Clause 6.3 covers changes that affect the environmental management system as a whole.
What counts as a change under ISO 14001 clause 6.3?
Any change that affects or can affect the system, such as new equipment, new chemicals, changed compliance obligations, new contractors, acquisitions or business disruption. Annex A.6.3 gives examples.
Can we use our ISO 45001 management of change form for ISO 14001?
Yes. One change process can serve several systems, provided it asks the environmental questions and the records show they were answered before the change went live.
How will an auditor test clause 6.3?
Expect the auditor to pick a real change made since the last audit and trace it through the aspects register, compliance obligations, risks and opportunities, training and documents.
Which ASC course covers clause 6.3 and the other transition builds?
Transition to ISO 14001:2026 covers planning of changes as a module 2 build and then links it to aspects, externally provided processes, the audit programme and management review, so a change on your site leaves the trail an auditor expects.
R1 950, all lessons included. No VAT is charged, so the price shown is the price paid. Teams of five or more: contact ASC for a team rate.
- 22 lessons in 4 modules, about 8 hours, self paced on your phone
- Module 2 builds planning of changes (6.3) and externally provided processes (8.1)
- A delta check, an evidence position on every change, a dated action plan and a readiness score
- Scenario checks after every few lessons, marked automatically with feedback that names the lesson to go back to
- 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, pass mark 70 percent
- Is it for me? Yes, if your site holds an ISO 14001:2015 certificate and you own its change process, audits or registers.
- How long does it take? About 8 hours in total, in lessons of roughly 10 to 20 minutes each.
- Will it work at my site? Yes. Run one of your own recent changes through the method, or use a case site change.
No certificate yet? ISO 14001:2026 Understanding and Implementation (R4 800) builds the change record with the rest of the system. Want the basics first? Introduction to ISO 14001:2026 is R1 495. Compare all four on the ASC ISO 14001 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 45001:2018, Occupational health and safety management systems, ISO
- ISO 22000:2018, Food safety management systems, ISO
- National Environmental Management: Waste Act 59 of 2008