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This paper seeks to understand what factors contribute to voluntary adoption of the ISO 14001 environmental management system by private sector facilities in Japan. A model based on regulatory, competitiveness, social responsibility and organization theory is applied to 1999 survey data. Analysis shows systematically different factors to be important indicators of voluntarism in different industries and for facilities at different stages of certification. First adopters and second adopters appear to be fundamentally different types of organizations driven by different internal and external factors. Although results do not indicate a clear causal linkage between ISO adoption and greening activity, evidence shows that at least two different stages of adoption have taken place in Japan and that ISO adoption is associated with environmental action. Copyright © 2002 John Wiley & Sons, Ltd. and ERP Environment [ABSTRACT FROM AUTHOR]