This paper aims to specify the conceptual and operational limits of codified environmental management systems (EMSs). Taking technical standardization as a departure-point, it is argued that key shortcomings regarding the contribution of EMSs towards environmental performance improvement (and thus ecological sustainability) can be identified: First, there are limitations to the self-regulatory framework adopted by organizations. Second, there are problems inherent within the development of EMS from prior management systems approaches, mostly based on a narrow and limited definition of quality. Third, there are errors of implementation and associated certification which compound a lack of progress in environmental improvement and progress towards sustainability. The implications of these limitations are presented and it is demonstrated that they are compounded by an appearance of progress, when in reality, little is changing. The authors point out that this failure of system based self-regulation argues for a move to performance based regime, driven if necessary by regulation
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