The Environmental Coordinator’s Annual Report in 3 questions

1. For which companies is the annual report mandatory?

The annual report is only mandatory for companies that must have an environmental coordinator environmental coordinator. Whether or not you need to appoint a coordinator (internal or external) depends on the class to which your organisation belongs. That classification is based on the environmental impact of your activities.

• class 1: the most harmful activity, such as scrap processing, petrochemicals, and the production of building materials;

• class 2: a less harmful activity, e.g. metal and woodworking plants and petrol stations without LPG;

• class 3: the least harmful activity, like bakeries, car garages, and office buildings.

If your company falls under class 1, you have to appoint an environmental coordinator and thus also submit an annual report. Certain organisations under class 2 also have that obligation. Your environmental and regulatory permits will tell you to which category the business belongs.

The obligation to employ an environmental coordinator (and submit an annual report) only applies in Flanders. So the rule does not apply in Brussels and Wallonia. That doesn’t mean you don’t have to pay attention to environmental impacts. But the law does not require you to designate a specific person for it.

2. What does the report contain?

Submitting an annual report is one of the environmental coordinator’s legal duties. After all, they are responsible for your organisation’s environmental policy.

In the report, the environmental coordinator describes, among other things:

• the various environmental actions they have taken;

• the recommendations they have proposed to the board;

• how your organisation has followed these recommendations.

Otherwise, there are no specific requirements in terms of form and content. As a result, annual reports vary in practice.

This structure provides guidance:

1. the administrative data: the details of your organisation and environmental coordinator and the description of your activities;

2. the permits: the environmental and regulatory permits, special conditions, derogations obtained, etc.;

3. the legal tasks: an overview of company inspection rounds, follow-up of recommendations and periodic audits, external communication, etc.;

4. environmental domains: analyses, measurements, and studies in the fields of air, water, soil, noise, and waste;

5. a general conclusion.

3. What happens to the report?

The annual report must be available to both the management and the works council and the Committee for Prevention and Protection at Work (CPPW) by 1 April. If you do not have social consultation bodies, the trade union delegation must be able to see the report.

At a meeting, the environmental coordinator goes over their report with the CPPW delegates, where they are allowed to ask questions about the content.