Substantial change
Also known as belangrijke wijziging
What does "Substantial change" mean under the IED?
A change in the nature or functioning, or an extension, of an installation or combustion plant, waste incineration plant or waste co-incineration plant which may have significant negative effects on human health or the environment
Defined in / by
- IED (32010L0075), Article 3, point (9)
Last updated: 14 October 2026.
When a change needs a new permit
A substantial change needs a new permit. Article 20(1) requires the operator to inform the competent authority of any planned change in the nature or functioning, or any extension, of the installation. Article 20(2) requires that no substantial change planned by the operator is made without a permit granted in accordance with the Directive.
The test in the definition is whether the change may have significant negative effects on human health or the environment. Article 20(3) adds a size rule: any change or extension is deemed to be substantial if the change or extension in itself reaches the capacity thresholds set out in Annex I.
The 2024 amendment left the definition unchanged, but it gave a substantial change a second consequence. Under Article 3(2) of Directive (EU) 2024/1785, the amended permit provisions apply to an installation already permitted when its permit is granted or updated under Article 20(2), unless an earlier date applies. A substantial change after 1 July 2026 can therefore bring the new rules forward for that installation.
Questions and answers
Does every change to an IED installation need a new permit?
No. The operator informs the competent authority of any planned change (Article 20(1)). Only a substantial change needs a permit granted in accordance with the Directive (Article 20(2)).
When is an extension automatically a substantial change?
When the change or extension in itself reaches the capacity thresholds set out in Annex I (Article 20(3)).
Sources
Directive 2010/75/EU on industrial emissions, consolidated text of 4 August 2024EUR-Lex · 4 August 2024
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control)EUR-Lex · 17 December 2010
Directive (EU) 2024/1785 amending Directive 2010/75/EU on industrial emissions and Council Directive 1999/31/EC on the landfill of wasteEUR-Lex · 15 July 2024
Related
Regulations · 1
Industrial Emissions Directive (IED 2.0)
The revised Industrial Emissions Directive is Directive (EU) 2024/1785. Member States had to transpose it by 1 July 2026, and none had notified full transposition by 25 September 2026. Operators need an environmental management system by 1 July 2027, and large pig and poultry farms follow from 2030. The Dutch bill is before the Eerste Kamer.