In 2026 (just like any other year), if you’re an EHS professional at a high-risk site in Belgium or the Netherlands, there are plenty of regulatory changes to keep up to date with. PFAS rules converge. Exposure limits drop. Permitting becomes less forgiving. Documentation that “has always been fine” suddenly needs to be reviewed.

Sometimes the challenge is knowing these regulations exist or have changed. But often, the real difficulty is knowing where they touch your site and turning that knowledge into concrete actions before inspections, projects, or shutdowns force the issue.

Below you’ll find the EHS regulatory changes coming into effect around 2026 that are most likely to impact high-risk industrial sites in the Benelux. You’ll see where risk shows up operationally, and what typically goes wrong when it’s missed.

And if you’re short on time, there’s a practical readiness checklist to help you turn awareness into action.

PFAS: when fire safety creates environmental risk 

PFAS has been “coming” for years. But in 2026, it will become a site-level problem, as several EU rules converge, affecting packaging, firefighting systems, water management, and contaminated soil.

What’s changing in 2026 

• The EU Packaging and Packaging Waste Regulation applies from 12 August 2026, restricting PFAS in food-contact packaging

• The EU has adopted a REACH restriction on PFHxA, with phased bans starting in 2026, including firefighting foams

• The updated EU Drinking Water Directive introduces PFAS limits from 12 January 2026

 

Where this hits operations 

• Fixed foam systems in tank farms, warehouses, and high-hazard storage areas

• Firewater retention, bunds, drainage systems, and soil around high-risk installations

• On-site water supply, groundwater monitoring, and wastewater discharge

• Legacy contamination from historic foam use at Seveso and COMAH-type sites

In most cases, these risks surface when EHS is asked to explain why something wasn’t flagged earlier.

 

What gets you in trouble in 2026 

• Firefighting foam still compliant for safety, but non-compliant environmentally

• No clear picture of where PFAS-contaminated firewater could end up

• PFAS risks split across EHS, emergency response, and maintenance, with no single owner

 

If this sounds like your site… 

Large warehouses with foam deluge systems, tank farms, or chemical storage areas where firewater containment was designed long before PFAS was a concern.

 

How TenForce helps 

TenForce can help you make PFAS risks visible and reviewable:

• Using Audits & Inspections to assess foam systems, bunds, and firewater containment

• Capturing PFAS-related findings and near-misses in Incident Management

• Following up actions through CAPA, with clear ownership and deadlines

• Keeping inspection evidence and decisions accessible in Document Control

Lead + diisocyanates: when lower limits reach occupational health 

The EU has updated binding occupational exposure limit values (BOELVs) for lead and diisocyanates, with Member States required to implement them by spring 2026. These limits directly affect how exposure is assessed, monitored, and acted on.

Put simply, for prevention advisers, occupational physicians/arbeidsarts/bedrijfsarts and worker representatives, this is where 2026 limits will bite on your site.

 

What’s changing in 2026 

• Significantly lower BOELVs for lead

• The first-ever binding EU exposure limit for diisocyanates

• National enforcement (in Belgium and the Netherlands) is expected from April 2026 onwards

Sites that were compliant under the old limits may not be under the new ones.

 

Where this hits operations 

• Insulation, coatings, adhesives, and polyurethane-based processes

• Maintenance workshops, repairs, and refurbishment activities

• Recycling and reprocessing operations

• Occupational health surveillance and medical monitoring programs

• Medical removal criteria, return-to-work decisions, and fitness-for-task assessments

This is where EHS and occupational health have to move together.

 

What gets you in trouble in 2026 

• Exposure levels below old limits but above new BOELVs

• Health surveillance protocols not updated to reflect new thresholds

• No documented criteria for temporary or permanent medical removal

• Inconsistent decisions around return to work after elevated exposure

If this sounds like your site… 

Insulation production, PU processing, maintenance workshops, or batch operations where exposure varies day-to-day and isn’t always predictable.

 

How TenForce helps 

TenForce can help you to keep exposure-related work structured and defensible:

• Reviewing exposure controls and measurements through Audits & Inspections

• Logging exceedances or concerns in Incident Management when thresholds change

• Tracking required follow-up actions via CAPA, not ad-hoc emails

• Keeping procedures, measurement reports, and decisions aligned in Document Control

Environmental permits in 2026: why “minor changes” aren’t minor anymore 

In both the Netherlands and Flanders, nitrogen-related permitting has become less forgiving.

What used to pass as a routine change (like upgrading a boiler, adding capacity, or extending operating hours) can now trigger additional environmental assessments or even a nature permit, often very late in the project.

For EHS teams, this is less about emissions targets and more about preventing delays to projects you’re expected to have flagged early.

 

What’s changing in 2026 

• Netherlands: stricter interpretation of internal netting (“intern salderen”) means more projects may require a nature permit

• Flanders: nitrogen rules are formalized under the stikstofdecreet, with less room for interpretation

• And if nitrogen constraints weren’t already tightening the screws, Flanders has removed the project-MER exemption route (from Dec 2025), meaning more projects require documented environmental screening

 

Where this hits operations 

• Energy and utility upgrades (boilers, furnaces, generators)

• Capacity increases, line extensions, or higher throughput

• Shutdown and turnaround modifications

• Infrastructure or logistics changes near protected areas

• Projects near Natura 2000 areas

Most of these are everyday industrial projects, not exceptional ones.

 

What gets you in trouble in 2026 

• Projects labelled “minor” without a documented nitrogen assessment

• Environmental screening started after the engineering design was fixed

• Permitting assumptions that don’t reflect current case law or guidance

 

If this sounds like your site… 

Manufacturing plants with planning capacity upgrades, boiler replacements, or process changes under tight capex timelines.

 

How TenForce helps 

TenForce can help you bring environmental permitting risks into the open early:

• Using Management of Change to assess environmental impacts before designs are fixed

• Verifying assumptions and conditions through targeted Audits & Inspections

• Tracking regulatory obligations and permit conditions in Compliance Management

• Keeping environmental studies and approvals accessible in Document Control

Asbestos: when routine work derails critical paths 

The EU has revised the asbestos-at-work rules, with Member States required to transpose them by 21 December 2025. In practice, 2026 is when on-site expectations tighten.

What’s changing in 2026 

• Stricter requirements for asbestos exposure control and worker protection

• Fewer exemptions for short-duration or low-intensity work

• Higher expectations for training, procedures, and documentation

 

Where this hits operations 

• Maintenance and repair work

• Shutdowns, turnarounds, and refurbishment projects

• Contractor-led insulation removal and demolition

• “Minor” facility changes where asbestos is discovered late

 

What gets you in trouble in 2026 

• Asbestos discovered mid-shutdown with no contingency plan

• Work stopped because permits and scopes don’t cover findings

• Critical-path delays caused by “unexpected” asbestos in known legacy areas

 

If this sounds like your site… 

Older chemical plants, heavy industry, or multi-contractor turnarounds running against fixed restart dates.

 

How TenForce helps 

TenForce can help you manage asbestos risk before tools come out:

• Embedding asbestos checks into Permit to Work processes for maintenance and shutdowns

• Recording discoveries or deviations in Incident Management

• Tracking corrective actions with CAPA, backed by clear documentation

Chemical classification: when “nothing changed” still changes everything 

Under the EU CLP Regulation, new hazard classes now apply, including endocrine disruptors and persistent or mobile substances. For mixtures, these changes apply from May 2026. That makes 2026 the year when SDS updates, labels, and internal registers need to line up properly.

What’s changing in 2026 

• New CLP hazard classes apply to mixtures

• Classifications, labels, and SDS may change (even if the product hasn’t)

• Hazard logic becomes more consistent across EU frameworks

Where this hits operations 

• Chemical registers and inventories

• Safety Data Sheets and labelling

• Storage rules and internal procedures

• Seveso documentation and safety reports

• Training materials for workers handling chemicals

What gets you in trouble in 2026 

• Safety reports based on outdated classifications

• Inconsistent hazard data across SDS, registers, and Seveso files

• Inspectors flagging mismatches rather than substance use itself

If this sounds like your site… 

Seveso installations, batch reactors, or sites with large chemical inventories that haven’t materially changed in years.

How TenForce helps 

TenForce can help you to keep chemical compliance consistent and inspection-ready:

• Maintaining up-to-date obligations and reviews in Compliance Management

• Managing SDS, classifications, and safety reports through Document Control

• Verifying alignment during Audits & Inspections

• Using Management of Change when classification updates affect Seveso status

Not to manage chemistry, but to prevent silent misalignment from becoming a finding.

 

Your 2026 EHS readiness checklist 

For EHS managers, prevention advisers, and process safety engineers, the challenge in 2026 is being able to answer three questions with confidence:

• Where do these rules touch our site?

• What have we already checked—and what haven’t we?

• Can we show that we acted early and deliberately?

That’s why we created a 2026 EHS readiness checklist for high-risk sites. It turns regulatory change into clear site-level review points, so you can prioritize actions, assign ownership, and show that risks were addressed deliberately.

Download the checklist and work through it with your team.

A few focused reviews now are far easier than explaining surprises later.