.svg)
Do you work for a company with more than 500 employees in mainland France? Or for an organization with 250 employees in overseas departments?
Since 2010, you have been required to publish your company's Greenhouse Gas Emission Report, known as BEGES, every four years on the ADEME website.
However, the adoption of Decree No. 2022-982 of July 1, 2022, changes the rules, making the regulatory BEGES more demanding and comprehensive.
Thus, since January 1, 2023, the BEGES has become more ambitious regarding GHG emission accounting, particularly on 4 key points you absolutely need to know to remain compliant and avoid penalties.
1. Indirect Emission Accounting Made Mandatory
Until now, only direct emissions (Scope 1) and energy consumption-related emissions (Scope 2) were mandatory under BEGES.
Now, with the new decree coming into force, organizations subject to BEGES must mandatorily include their significant indirect emissions (Scope 3) in their GHG accounting.
Although often overlooked due to their complexity in accounting, Scope 3 indirect emissions very frequently represent the largest category of emissions in companies' carbon footprints.
In certain sectors, such as manufacturing industries, 80 to 90% of companies' emissions are attributable to Scope 3, and more specifically to procurement.
Ultimately, this evolution of BEGES only strengthens the already highly strategic position of procurement within companies. Integrating rigorous carbon criteria, in addition to existing socio-economic and environmental criteria, into responsible procurement strategies will become a necessity for many businesses.
What are "significant indirect emissions"?
Significant indirect emissions include Scope 2 emissions related to energy and Scope 3 emissions related to transport and purchased and sold products.
Companies must identify these significant indirect emissions based on a precise methodology and criteria. Among these, the magnitude criterion must be predominant, representing at least 80% of your indirect emissions. The 5 other criteria are optional:
- level of influence,
- strategic importance and vulnerability,
- sector-specific guidelines,
- subcontracting,
- employee engagement,
2. New obligation to establish a transition plan
The second major development of the BEGES concerns the actionability of the carbon assessment.
Moving forward, companies subject to BEGES must develop a “transition plan” comprising:
- a review of past actions,
- medium and long-term objectives,
- an action plan with quantified expected reductions, for each scope.
This new measure aims toencourage companies to implement a comprehensive, precise, and actionable carbon strategy. This is a major evolution for organizations that must shift from a “reporting” vision to a “management” vision.
This change should lead to profound transformations in business activities, with carbon becoming an essential management criterion.
3. Simplified carbon footprint consolidation
The new BEGES decree facilitates the production of a carbon footprint report for subsidiaries of the same group.
Now, legal entities (SIREN) can more easily, and in accordance with the provisions of Article L. 233-16 of the Commercial Code, consolidate the reports of all or some of their establishments (SIRET) within their GHG emissions report.
Specifically, the requirement for companies within the same group to share the same NAF code at level II to consolidate their Greenhouse Gas Emissions Report has been lifted.
Unfortunately, several limitations persist, particularly for groups with foreign subsidiaries, who can only consolidate their BEGES with companies located on French soil.
4. Stronger penalties for BEGES non-compliance
Finally, the last point to note concerns the fines applied, which have been increased.
[SEG 9]
Now, companies that fail to produce their mandatory BEGES will have to pay
€10,000 or €20,000 in the event of a repeat offense.
[SEG 11]
This amount is almost 7 times higher compared to the previous version of the BEGES, which stipulated a fine of €1,500.
[SEG 12]
Conclusion: how to comply with the new BEGES regulatory requirements?
[SEG 13]
It's clear that the new BEGES obligations are part of
Therefore, staying up-to-date with regulations is now the bare minimum to avoid penalties and, above all, to maintain competitiveness. This can, and must, involve the deployment of a
carbon footprint platform .Are you looking to ensure your company can meet the requirements of the new BEGES?
Contact the Tennaxia team.
Sources
1. https://www.ecologie.gouv.fr/decret-bilan-des-emissions-gaz-effet-serre-beges
2. https://bilans-ges.ademe.fr/