Primary Source
A brief from The Mender-Haüs Corporation
The month in one line
ISO 9001:2015 was withdrawn on the day the 2026 edition published, and the document that sets your transition deadline does not exist yet
Both halves of that are checkable, and both are below with the stage codes and the resolution number. The gap between them is where the guesswork is coming from.
Item one
ISO 9001:2026 is published, and 2015 is already gone
ISO 9001:2026, sixth edition, is at ISO stage 60.60 — International Standard published — dated 16 September 2026.
ISO 9001:2015 is at stage 95.99 — Withdrawal of International Standard — dated 16 September 2026. The same day.
ISO treats withdrawal and replacement as the same event; the 2015 catalogue entry records both, at 95.99 and as superseded by the 2026 edition. What it does not record is a period during which the 2015 edition stays current. It is not being phased out, and it is not the standard any longer.
Your certificate is a separate question, and ISO’s own page says so — it directs certified organizations to their certification body for transition arrangements. Item two is about what those arrangements rest on.
This is the second time in five months. ISO 14001:2015 went to 95.99 on 15 April 2026. Same code, same day-of-publication timing, same consequence for anyone whose checklists carry clause numbers.
What ISO itself names as changed
The standard’s own foreword states six main changes, and the sixth edition also incorporates Amendment 1:2024:
- Core ISO management system terms and definitions brought into Clause 3. ISO 9000 remains the normative reference for the rest.
- Quality culture and ethical behaviour introduced into the requirements, particularly around leadership, awareness, and the environment for the operation of processes.
- Risks and opportunities separated, with actions to address each considered separately.
- Management of change strengthened — the requirements on changes to the quality management system reinforced.
- Annex A revised to give enhanced clarification of structure, terminology and intent, as informative text introducing no new requirements.
- Annex B removed.
ISO’s own announcement adds one more: the sixth edition adopts the latest harmonized structure common to ISO management system standards.
What that means structurally
One of those is renumbering, and renumbering is what breaks documents.
Risks and opportunities are now separated on the page. Where the 2015 edition ran them together under a single 6.1, the 2026 edition carries 6.1.1 Determining risks and opportunities, 6.1.2 Actions to address risks, and 6.1.3 Actions to address opportunities. An organization that has been treating opportunity as the optional half of a risk register now has a clause pointed at it.
Clause 6.3, Planning of changes, is not new — it carried the same number in the 2015 edition, and what the 2026 edition did was reinforce it. The change is on the environmental side: ISO 14001:2026 gained a 6.3 with the same title in April, where the 2015 edition had none. For the first time both standards handle planned change at the same clause number, which is the one piece of good news in this issue for anyone running an integrated system.
Every procedure, form, register and audit checklist that cites a 2015 clause number needs checking against the new numbering. None of it is difficult. All of it is finite. It is almost always found later than it should be.
Item two
Nobody has published your deadline
If you have been quoted a date for completing your ISO 9001 transition, somebody estimated it. Here is the chain, in order, with the documents.
ISO publishes standards. ISO does not set transition periods for certified organizations, and ISO’s own announcement of the 2026 edition says nothing about transition timing at all.
The transition period is set by the accreditation cooperation, then implemented by accreditation bodies and certification bodies. That cooperation is now Global ACI, which took over the roles of the International Accreditation Forum and the International Laboratory Accreditation Cooperation on 1 January 2026.
Global ACI Resolution 2025-18 records that it assumes responsibility for the continued development and maintenance of the IAF documents then under review or revision. Two of those are named in the resolution as transition requirements for ISO 9001 and transition requirements for ISO 14001.
Under review or revision. Not issued. As at 17 September 2026, no such mandatory document appears in Global ACI’s published document list.
Three years is the working expectation because three years is what the last several transitions ran. It is a precedent, not a published requirement, and it is not a date you can put in a plan and defend. ISO 14001 is in the same position, five months further along — published 15 April 2026, 2015 edition withdrawn the same day, transition requirements not yet issued.
What you can do without the date
Everything that does not depend on it, which is most of it. Buy the standard and read it. Run the clause-number check across your documented information. Identify which of your processes the renumbering actually reaches. Ask your certification body, in writing, what date it is currently operating to and on what published basis — the answer tells you whether they are working from a document or from the same precedent everyone else is.
What you should not do is buy a transition program priced against a deadline nobody has published.
Item three
A scheme anchored to a date that does not exist
Issue 01 made the point that a sector scheme cannot keep pointing at a superseded edition of the standard underneath it, and that IATF 16949 was waiting on ISO 9001. ISO 9001 has now published. Here is where that went.
IATF Stakeholder Communiqué SC-2026-005, issued July 2026, states that the second edition of IATF 16949 is planned for publication in mid-2027, and that the end of its transition time will be aligned with the end of the ISO 9001 transition.
Read those two items together. IATF has anchored its transition end to the end of an ISO 9001 transition that has not been set. That is a reasonable thing for IATF to do — it is the only sensible anchor available — but if you hold IATF 16949 it means your automotive deadline is now downstream of a date nobody has published, one step removed.
The communiqué names five priorities for the revision: simplification and ease of audit; software quality assurance for embedded software across its lifecycle; Tier N supply chain management on a risk basis; launch management; and better handling of customer-specific requirements, with the possibility of common CSRs moving into the standard itself.
That last one is worth watching. If common customer-specific requirements migrate into the standard, they stop being contractual and become auditable.
Item four
The Global ACI mark, as promised
Issue 01 said this brief would report whether the mark authorization decision landed on schedule. It has not, and there is a reason.
Global ACI’s published position is that no notification to Full Members, and no authorisation for use of the Global ACI MRA Mark, shall be made before a formal decision at the MRAC meeting in October 2026. Full Members are not currently authorised to use the mark in any economy.
Authorization is also not a single global switch. It follows legal availability of the mark economy by economy — trademark opposition periods expiring, objections resolved — and then formal notification from the Secretariat. Once that notification issues in your economy, continued use of the old IAF or ILAC mark on new, renewed, reissued or amended accreditation documents becomes a nonconformance. Accreditation documents issued without a fixed expiry date may remain valid in their existing form until an administrative action occurs — renewal, re-issue, a scope change, or a change to the accredited legal entity.
Still the answer Issue 01 gave. Nothing to do. Your certificate is unaffected. Where it will matter is at your next renewal or re-issue after your accreditation body is notified.
Item five
OSHA hazard communication: the date in front of you is 20 November, and one official page still shows the old one
Away from ISO entirely, and on a much shorter fuse.
OSHA published its updated Hazard Communication Standard on 20 May 2024 at 89 FR 44144, effective 19 July 2024, aligning 29 CFR 1910.1200 primarily with Revision 7 of the GHS. A final rule published 15 January 2026 at 91 FR 1695 then moved every compliance date back four months.
| Provision | Who it binds | Date |
|---|---|---|
| 1910.1200(j)(2)(i)substances | Manufacturers, importers, distributors | 19 May 2026passed |
| 1910.1200(j)(2)(ii)substances | Employers | 20 November 2026the one in front of you |
| 1910.1200(j)(3)(i)mixtures | Manufacturers, importers, distributors | 19 November 2027 |
| 1910.1200(j)(3)(ii)mixtures | Employers | 19 May 2028 |
As at 17 September 2026, OSHA’s own standard page for 1910.1200 still displays the pre-extension dates. The eCFR, current to 15 September 2026, carries the correct ones. Two official sources, two calendars, and the wrong one is the one most people reach first.
The guidance OSHA was waiting on has landed
The extension was granted because OSHA’s own compliance guidance was not ready. It is now. The agency’s Questions and Answers document for the 2024 update has been published, and its compliance-date table carries the post-extension dates. More consequentially, the inspection directive — CPL 02-02-079 — took effect 19 May 2026, cancelling the directive that had governed HazCom inspections since 2015. Anyone still describing the 2024 rule as “not yet enforced” is describing the position as it stood in January.
What the directive tells inspectors: during the transition period an employer may comply with HCS 2012, with HCS 2024, or with both, and is not cited for choosing — unless it complies with neither. That is the whole of the latitude. It is not a grace period, and it ends on your applicable date.
What 20 November actually requires
Narrower than the summaries suggest. By that date, for substances, all employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6), update the hazard communication program required by (h)(1), and provide additional employee training under (h)(3) for newly identified physical hazards, health hazards or other hazards.
Three things follow. It is triggered by what is newly identified, not by the calendar alone. It reaches in-plant labeling under (f)(6), not shipped container labels — those were the manufacturer’s obligation and were due in May. And it is owed at every site; the duty does not discharge at corporate level.
Two things that catch people out
Your safety data sheet library holds two editions. Paragraph (j)(4) permits manufacturers, importers, distributors and employers to comply with the updated section, or with 1910.1200 as revised 1 July 2023, or both, from 20 May 2024 until their own applicable date. Nothing on a document tells you which edition you are holding.
EPCRA changes too, on a different deadline. An EPA rule published 22 June 2026 at 91 FR 37022, effective 21 August 2026, replaces the 24 EPCRA hazard categories with all 118 OSHA hazard categories and subcategories. Compliance date 1 January 2028; first reporting year 2027, filed by 1 March 2028. Your Tier II report changes, through a different agency, on a third calendar.
If you operate in a State Plan state, there is a fourth. State Plans with their own hazard communication standards must adopt provisions at least as effective as the final rule. What binds you is the text your state actually adopted, so check it rather than assuming it matches the federal version line for line.
Next issue
November
The requirement in the 2024 HazCom rule that will actually cost manufacturers money: classification for reaction products of known or reasonably anticipated downstream uses, how far OSHA says that reaches, and the four limits the agency has put on it. Plus whether the Global ACI mark decision landed in October, and whether anyone has published an ISO 9001 transition period.
Checked against
- ISO catalogue entry for ISO 9001:2026 — sixth edition, stage 60.60, dated 2026-09-16.
- ISO catalogue entry for ISO 9001:2015 — stage 95.99, Withdrawal of International Standard, dated 2026-09-16, superseded by ISO 9001:2026.
- ISO catalogue entry for ISO 14001:2015 — stage 95.99, 15 April 2026.
- The published text of ISO 9001:2026 — the foreword, for the six main changes and the incorporation of ISO 9001:2015/Amd 1:2024, and Clause 6 for the numbering of 6.1.1, 6.1.2, 6.1.3 and 6.3; and the published text of ISO 14001:2026, Clause 6, for 6.3 Planning of changes. Both read from licensed single-user copies.
- ISO news release on the publication of ISO 9001:2026, September 2026, for the adoption of the latest harmonized structure.
- Global ACI Resolution 2025-18, Continuation of IAF Technical Work Under the Global Accreditation Cooperation Incorporated, which names among the IAF documents under review or revision a transition requirements document for ISO 9001 and one for ISO 14001.
- Global ACI published document list, reviewed 17 September 2026 — no mandatory document setting a transition period for either standard appears in it.
- Global ACI Frequently Asked Questions, on MRA Mark authorisation, the October 2026 MRAC decision and the validity of existing accreditation documents; and Global ACI-MRA-006 on use of the MRA Mark by accreditation bodies and conformity assessment bodies and claims of accreditation status, v1.0, issued 23 October 2025.
- IATF Stakeholder Communiqué SC-2026-005, IATF 16949 2nd edition update information, issued July 2026.
- OSHA, Hazard Communication Standard; Final Rule, 89 FR 44144, 20 May 2024, document 2024-08568, effective 19 July 2024 — with the correction and technical amendment of 9 October 2024, document 2024-23144; the corrections at 91 FR 562, published and effective 8 January 2026, document 2026-00147; and the further correction at 91 FR 6760, 13 February 2026, document C1-2026-00147.
- OSHA, 91 FR 1695, published and effective 15 January 2026, document 2026-00653 — the four-month extension of the compliance dates at 1910.1200(j)(2) and (j)(3); the regulatory text of 1910.1200(j)(2), (j)(3) and (j)(4) as it appears in the eCFR, current to 15 September 2026; OSHA’s own standard page for 1910.1200, retrieved 17 September 2026, still showing the pre-extension dates; OSHA’s Questions and Answers for the 2024 update; and OSHA Instruction CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024), effective 19 May 2026, cancelling CPL 02-02-079 of 9 July 2015.
- EPA, EPCRA Hazardous Chemical Inventory Reporting Requirements: Conformity With the 2024 OSHA Hazard Communication Standard, 91 FR 37022, published 22 June 2026, document 2026-12426, effective 21 August 2026.
Every date, stage code and citation in this brief was read from the issuing body’s own document on 17 September 2026. Where a thing has not been decided, this brief says so rather than estimating. This is commentary on published documents and is not legal advice.
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