Custom software for the ZZS inventory and reporting
For substances of very high concern, the question shifts over time. First it is about where the substance is found; then whether you can demonstrate what you have considered over the past five years and why you have not done otherwise. That second part is a dossier, and it only grows if someone keeps it up to date.
What the dossier should contain
Article 5.23 of the Activities Decree (Besluit activiteiten leefomgeving) requires two things once every five years: data on the extent to which substances of very high concern (SVHC) are emitted to air or water, and the avoidance and reduction programmes under Article 5.24. You submit this data electronically, using the form the Ministry of Infrastructure and Water Management makes available on the e-MJV; mandatory since 1 January 2025.
Article 5.24 sets out what that programme must contain: options for avoiding use and, where avoidance is not possible, techniques to prevent and limit emissions, with information on operational reliability, costs and cross-media effects. The techniques also require information on efficiency and validation. In effect, it is a justification of your decisions.
Meanwhile, the list these obligations rest on keeps changing. RIVM updates the SVHC list at least twice a year, and in practice more often; the May 2026 update added 36 substances. Since November 2024, all PFAS fall under it, and in July 2026 the list of potential SVHCs was replaced by the Watch List of substances under European assessment. An inventory drawn up five years ago is no longer accurate today.
How we build this
Here, the inventory is the unit, not the measurement. What you submit comes from the field, but what you must be able to defend is the reasoning around it.
For each substance: where it is found, in which product and process, and on what basis it is an SVHC. Without that basis, you cannot tell what a change in the list affects.
With every update, review your substances again. That is a reassessment, not an import.
Every consideration with its date, justification and outcome. A programme written in the final year reads that way too.
For each substance and each emission point, the highest annual average concentration and the highest annual load over the period, for air and water.
What the software actually does
The inventory and its basis carry the whole. What else you need depends on the number of substances and sites you operate.
The inventory with its basis
For each substance where it is found and why it is an SVHC: hazard classification, candidate list, OSPAR, the Water Framework Directive or the POP Regulation. That basis determines what a list change means for you.
Alert on a new list version
The list is updated several times a year. We flag which of your substances have been affected, so that reassessment becomes a task rather than a discovery.
The reduction programme as a file
Avoided use, techniques considered, costs and operational reliability, cross-media effects, efficiency and validation, each with its date and decision-maker.
Annual average and annual load per point
For each substance and each emission point, the highest annual average concentration and the highest annual load over the reporting period, for air and water.
Deadline monitoring per site
There is no national deadline; the timing varies by company and by competent authority. With several sites, several clocks are running.
Linking to field measurements
Measurements and samples originate at the emission point. We collect them through integrations with your laboratory and with the on-site register.
Who we build for
Where the centre of gravity lies differs greatly from company to company. Four situations.
Chemicals and process industry
Many substances, many emission points, and usually also a PRTR report with its own deadline. See also software for the chemical sector and work permits.
Metal, coating and surface treatment
The PFAS extension has affected agents that were long in common use. The question now is whether you can show which alternatives you considered. If explosion risk is present, there is ATEX software and zone control on the shop floor.
Businesses with multiple sites
Different environmental services, different timings, the same substances. A single inventory prevents each site from maintaining its own version, just as with the substance inventory and threshold assessment.
Environmental advisers and measurement agencies
You propose programmes to multiple clients. A single environment per client saves you from having to reconstruct a decision history each time, alongside your audit file.
Test your idea first: a working prototype in 1 day
With OneDayBuild, we turn your idea into something tangible in one day for €1,150, so you can see whether further development is worth the investment. Decide to go ahead with the full build? Then we credit the full cost.
Explore OneDayBuild →Technology and integrations
The substance list changes several times a year, and the basis for each substance changes with it. Everything relating to substances, bases and reporting fields should be configurable and retained with its history.
Why Appfront
The list shifts beneath your feet
We record the basis for each substance, so that an update produces a signal rather than a surprise at the next visit.
Five years is a file
We build the programme as a continuous record of decisions. What is written up only in the final year shows in the justification.
Your justification will be assessed
The competent authority looks at completeness, consistency and credibility. We ensure that every figure has a traceable origin you can point to.
We do not determine your obligation
Whether section 5.4.3 applies to your activity is for your environmental adviser to assess with the competent authority. We build the record that supports that justification.
Security and privacy
A substance inventory describes which substances are present in which products and processes. That touches on your formulation and your environmental position, and you will not want to share it more widely than necessary. We set access by role and by site, give an external consultancy only its own scope, and log every instance of access.
For this subject, the durability of the file is the crux. The competent authority assesses your data for completeness, consistency and credibility, and you remain responsible for its accuracy. A decision that can be written in after the fact undermines the whole. We therefore record every consideration and every value with a timestamp and person, and treat a correction as a visible correction alongside the original text. How we handle security ourselves is set out in our information security policy; reports from outside go through our CVD policy.
Frequently asked questions on ZZS management and submission
That abbreviation is not a designation in this regulation, so we do not use it substantively. The obligations are the information obligation for substances of very high concern, the avoidance and reduction programme, and the ZZS emissions database. If you mean something else, please let us know.
Article 5.23 of the Besluit activiteiten leefomgeving states: once every five years. There is no national date on which this happens for everyone at once; the timing differs by company. With multiple sites under different environmental services, those moments vary.
Article 5.24 lists four components: options for avoiding use; where that is not possible, techniques to prevent and limit emissions; information on operational reliability and the costs of those techniques; and information on transfer effects. The overview of techniques should also include information on efficiency and validation.
The familiar wording comes from the Activiteitenbesluit, which was repealed on 1 January 2024. Under the Environment and Planning Act (Omgevingswet), the duty is derived from the specific duty of care in article 2.11 of the Bal: take the measures that can reasonably be expected, limit the consequences as far as possible, and, where necessary, refrain from the activity. Article 5.23 is therefore titled inform and minimise.
Electronically, via the form that the Ministry of Infrastructure and Water Management makes available on the e-MJV; mandatory since 1 January 2025. For each substance and each emission point, you enter the highest annual average concentration and the highest annual load, for air and water. If you are also subject to PRTR, there is a fixed deadline for that: no later than 31 March of the year after the reporting year.
You still submit. For the substances used or generated in your process, you enter a value of zero. Only those who use no SVHC at all and generate none need suffice with a declaration in the database.
In July 2026, that list was replaced by the Signalling list of substances under European review. The requirements of section 5.4.3 do not apply to substances on it, because they do not yet meet the definition of an SVHC; the competent authority can still request information about them. The split in your inventory is therefore arranged differently from what you were used to.
The app is about recording on site: where the substance is, samples, measurements at the emission point. This page is about the system around it: the inventory, the programme and the submission. In practice, you build them on a single record, just as with Seveso software.
Not sure whether your inventory is still accurate?
Get out your substances list and find out when it was last checked against the current ZZS list (substances of very high concern). If that was more than a year ago, there are substances in your process whose status you don't know. We build this as a standalone application and as part of a broader custom software project.