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🔎 Things to remember
Decarbonizing industry is no longer a peripheral issue. It now lies at the intersection of several major challenges: regulatory compliance, energy cost control, competitiveness, customer expectations, pressure from the value chain, and credibility with investors. In this context, the question is no longer about producing yet another assessment, but about building a clear, manageable, and actionable roadmap.
Energy: The Key Driver of Transformation
In industry, energy is at the heart of the issue: energy consumption accounts for an average of 75% of greenhouse gas emissions. This fundamentally changes how we view the issue. Working toward decarbonization is not just about meeting climate goals; it’s about taking action in an area that impacts costs, resilience, and operational performance.
This reality explains why decarbonization can no longer be treated as a standalone reporting exercise. It is becoming a key factor in business decision-making, with direct implications for investment, competitiveness, and a company’s ability to demonstrate tangible progress to its stakeholders.
SMEs: A regulatory framework that requires a structured approach
The regulatory framework has been significantly strengthened. Affected legal entities must implement an energy management system if their average annual final energy consumption is 23.6 GWh or more. For consumption levels above 2.75 GWh, they must conduct an energy audit every four years if they have not implemented an energy management system. The action plan must be published in the annual report, and information regarding the fulfillment of these obligations must be submitted electronically within two months of the system’s certification or the completion of the audit.
The compliance timeline sets a clear course of action. Companies newly subject to the energy management system requirement must have a certified system in place by October 11, 2027, at the latest. Those newly subject to the audit requirement must conduct their first audit by October 11, 2026, at the latest. The average annual consumption used to determine these thresholds is the average of consumption over the three preceding calendar years.
Operational requirements are also being raised. The energy audit and energy management system must cover at least 80% of the final energy consumption of the company identified by its SIREN number, and consumption must be reported on ADEME’s dedicated platform. In other words, we are moving from a mindset of minimal compliance to one of traceable, documented, and managed energy management.
An energy audit is no longer just a deliverable
The decree of July 10, 2025, further reinforces this approach. The audit must be conducted in accordance with standard NF EN 16247-1:2022, supplemented by standards specific to buildings, processes, and transportation. Recommendations must be ranked according to return on investment, energy efficiency measures must be clearly identified, and internally conducted audits must justify the technical resources and expertise deployed.
For manufacturers, this changes the very nature of the issue. An audit is no longer just a document to be produced to meet a regulatory requirement; it becomes a basis for decision-making, a tool for prioritization, and a framework for balancing feasibility, profitability, and impact.
Photovoltaic shade structures: a real-world example of a challenge turned into a project
The issue of parking lots perfectly illustrates this shift. Under the APER Act, outdoor parking lots larger than 1,500 m² must be equipped, over at least half of their area, with shade structures that incorporate a renewable energy generation system. The law also provides for the possibility of sharing this requirement among adjacent parking lots, as well as several exemptions, particularly for technical, safety, architectural, heritage, environmental, or economic constraints.
For existing parks or those authorized within the scope of the law, the deadline is set for July 1, 2026, for areas of 10,000 m² or more, and for July 1, 2028, for those between 1,500 m² and 10,000 m². However, in practice, the issue is not limited to a threshold and a date. One must also take into account the calculation of the actual area covered, applicable exclusions, potential ICPE (Classified Industrial Installations) or hazardous goods transport restrictions, the conditions for justifying an exemption, and, depending on the case, the performance criteria and supply chain resilience of the panels. This is precisely what transforms a regulatory obligation into a genuine investment project.
The real challenge: making carbon footprints comparable over time
Measuring GHG emissions is the first step. Reliably comparing them over time is another. Acarbon footprint® can quickly become misleading if the physical scope changes, if emission factors shift, if the level of detail in the analysis is altered, or if data sources are replaced without a clear methodological framework. The robustness of the baseline is therefore just as important as the measurement itself.
Building a usable carbon baseline rests on four pillars. First, establish the right initial assumptions: the correct scope, the right capacity for action, accurate emission factors, and proper consideration of uncertainty. Next, define a methodology for collecting and validating data. Then, establish a framework for methodological changes: changes in scope, acquisitions, new data sources, modifications to emission factors, changes in accounting methods, or changes in the level of detail. Finally, version the baseline and perform rebaselining when necessary.
This approach transforms the value of carbon management. It enables organizations to track emissions by category and by site, compare multiple entities against one another, and obtain a truly actionable metric—one that is comprehensive, reliable, and detailed. Without this framework, the projected trajectory may remain unclear. With this framework, it becomes actionable.
Measuring isn't enough: we also need to simulate, prioritize, and manage
A robust decarbonization strategy relies not only on data collection. It also involves modeling actions, defining input metrics for simulations, and comparing multiple scenarios from two perspectives: carbon impact and financial impact. Only then can a company prioritize its projects, make informed investment decisions, and avoid action plans that are too generic to be effectively implemented.
The final step is organizational. To move from intention to action, we must establish clear governance structures and delegate decision-making authority to the entities that are actually driving the initiative. Without operational support, decarbonization remains merely a reporting exercise. With the right governance in place, it becomes a catalyst for transformation.
From Compliance to Sustainable Performance
What is at stake in the industry today is no longer simply the ability to meet a regulatory requirement. It is the ability to develop a comprehensive approach: identifying priority energy areas, incorporating new obligations, ensuring data reliability, establishing a baseline that is comparable over time, modeling actions, and organizing the governance structure needed to implement them. Other regulatory levers, from the MACF to the ETS, including the CEE and the BEGES, further reinforce this management approach.
For manufacturers, the question is no longer whether to decarbonize, but how to turn this challenge into a credible, profitable, and sustainable path forward. This is where the difference now lies between a company that merely endures the transition and one that turns it into a competitive advantage.
Learn more by downloading our white paper on decarbonizing industry.
