In a highly competitive global marketplace, Australian horticulture has traded on its ‘clean’ and ‘green’ image for many years. Although product quality, food safety and freedom from chemical residues (‘clean’) are routinely monitored, ‘green’ credentials are less readily proven. Social and market pressures for demonstration of environmentally responsible production are increasing with the introduction of product standards such as EUREPGAP. An Environmental Management System (EMS) is a potential tool to demonstrate environmental management, achieve environmental outcomes and manage risks, but is EMS appropriate for application to Australian horticulture? Major drivers for the Australian horticulture sector to address its environmental management performance are outlined. EMS is examined as a tool for achieving this outcome by exploring six factors that will influence its effectiveness: (i) complexity and diversity of the horticulture sector, (ii) the variety of expectations surrounding EMS programs, (iii) whether they can achieve environmental outcomes, (iv) whether they will be adopted by farmers, (v) scepticism towards assurance schemes and (vi) links with other programs and policy instruments. It is proposed that these factors are critical to the appropriate implementation of EMS in horticulture, and must be considered and addressed in the design, implementation and evaluation stages.