Since Amendment 1:2024, ISO 9001 clause 4.1 has required the organization to determine whether climate change is a relevant issue. ISO 9001:2026 carries this requirement into the main text. Factories have asked us whether this requirement obliges them to prepare a carbon inventory.

ISO 9001 does not require a carbon inventory. The guidance referred to in this article is Auditing Climate Change issues in ISO 9001, published in March 2024 by the ISO 9001 Auditing Practices Group, a joint group of ISO/TC 176 and the International Accreditation Forum. It states that the amendment "does not require an organization to have climate change initiatives unless it has been identified as a relevant issue to achieve the intended results of the QMS."

Why a factory may still need carbon data

The guidance describes the auditor's role as assessing whether the organization determined if climate change is relevant to its quality management system and, if it is, how the system addresses it. The guidance also notes that auditing the methods behind climate-related product claims may be outside the objectives of an ISO 9001 audit. The correctness of a carbon inventory calculation is therefore generally outside the scope of an ISO 9001 audit.

A factory can still be required to produce carbon data for reasons outside ISO 9001:

• Regulation. In Taiwan, the Ministry of Environment requires power, steel, petroleum refining, cement, semiconductor and display panel plants, and any facility whose direct and electricity-related emissions reach 25,000 tonnes CO₂e a year, to register an annual inventory by 30 April. In March 2025 the ministry extended the requirement to selected sectors with estimated emissions between 10,000 and 25,000 tonnes.
• Customers. Customers ask for company emissions, product carbon footprints, or embedded emissions for products that fall under the EU CBAM.
• The factory's own claims. If a catalogue or website describes a product as low carbon, clause 8.2.2 b) requires the factory to show that it can meet the claim. The guidance asks auditors to pay particular attention to such claims.

Passing the audit with a not relevant determination

The guidance lists three questions for the auditor:

1. Has the organization determined whether climate change is a relevant issue?
2. Does the organization's determination align with the statutory and regulatory requirements applicable to its products and services?
3. Does the organization's determination align with its contractual requirements?

A determination that climate change is not relevant is acceptable. The guidance itself notes that auditors will find organizations that have considered climate change and found it not relevant to their QMS. The record has to answer the three questions above, and we suggest that it covers the following points:

A finding can arise when the context record states "not relevant" but the auditor finds a customer request for emissions data in the contract review file, or a "green manufacturing" claim on the company website. The determination then contradicts the evidence, and the auditor will go back to 4.1 and ask how the assessment was made.

Proceeding when climate change is relevant

Step 1. Handle the issue inside the quality system

The guidance says that a relevant climate issue follows the same path as any other issue. The clauses involved are:

• 4.3 Scope. The factory decides whether the issue changes the QMS scope. The guidance gives the example of an organization that considered moving because of a higher flood risk at its current site.
• 6.1 Risks and opportunities. A risk can be a customer requirement for carbon data that the factory cannot yet meet. An opportunity can be a tender in which suppliers with carbon data are preferred.
• 8.2 Requirements for products. Contract review includes the customer's carbon requirements, and the factory accepts the order only when it can meet them.
• 8.4 External providers. The factory passes data requirements to its suppliers, for example a request for a carbon footprint of the steel it buys.
• 9.1 and 9.3. The data should come from reliable sources, and the management review should evaluate whether the actions were effective.

Step 2. Produce the carbon data the customer actually needs

An organizational inventory follows these steps: set the organizational boundary, list the emission sources, collect one year of activity data such as fuel, gas, electricity and refrigerant top-ups, apply the official emission factors, select a base year and write the inventory report. Third-party verification is added when a regulation or a customer requires it. A small or medium factory without a regulatory obligation can start with direct emissions and purchased electricity.

Using one data set for both purposes

The information collected for carbon data, such as material sources, process energy and production volumes, is also the evidence a credible 4.1 and 6.1 assessment needs. When one team uses one data set for both purposes, the factory avoids contradictions between the climate assessment and the carbon figures at the audit.

An ISO 9001 audit assesses whether the factory's conclusion on climate change is consistent with the applicable regulations, its contracts and its own claims, and it does not assess the quantity of emissions.

This article is based on the ISO 9001 Auditing Practices Group paper Auditing Climate Change issues in ISO 9001, Edition 1, 19 March 2024. The paper states that it has not been subject to a formal endorsement process by ISO or IAF. Taiwan inventory registration rules are summarised from the Ministry of Environment announcements as reported in 2025; check the current rules before relying on them.